 Chair LaPenna, I think we're ready to go. I'd like to call the February 26, 2024 housing authority regular meeting to order. Members of the public may view and listen to the meeting as noted on the city's website and noted on the agenda. As a matter of housekeeping, I'd like to remind the commissioners to keep their microphones muted unless they're speaking. The city of Santa Rosa is committed to creating a safe and inclusive environment from disrupt, free from disruption. We will not tolerate any hateful speech or actions and our well staff to monitor that everyone participates respectfully or they will be removed. If necessary, we will also immediately end the meeting. Mr. Clerk, would you please explain how public comments will be heard in today's meeting? At each agenda item, after the item is presented, the chair will ask for housing authority commissioner comments. After the commissioner comments, the chair will open the item for public comment. For members of the public attending in person, when the chair calls for public comments after an item is presented, please go to the closest public speaking podium in the upper tier of chambers. Once situated at the podium, the clerk will unmute your microphone and permit your comment to be heard. Public comments will be limited to three minutes per speaker per item. Public comments are limited to one comment per speaker per item. Additionally, there is one public comment period on today's agenda to speak on non-agenda matters. That'll be item number five. This is a time when any person may address the housing authority on matters not listed on this agenda but which are within the subject matter jurisdiction of the housing authority. Before I ask the clerk to do the roll call of attendance to assist with the streaming of the meeting and capturing the commissioners as they are speaking, I want to continue to remind the commissioners to please ask the chair to be recognized before speaking and making a comment. This will allow the camera to shift to a new speaker. Mr. Clerk, please call the roll. Just one moment. OK, we'll go ahead with a roll call for attendance. We will start with Commissioner Smith. Here. Commissioner Friedman. Commissioner Owen. Here. Commissioner Downey. Commissioner Conte. Here. Vice Chair Newton. Here. And Chair LaPenna. Here. Let the record reflect that all commissioners are present. Item three, statements of abstention. Are there any abstentions? Very none. We will proceed to item four, steady session. Rebecca Lane, the manager of housing, will present its review of the Housing Choice Voucher Program administrative draft plan. Rebecca. Thank you very much, Chair LaPenna. And good afternoon, commissioners. My name is Rebecca Lane. I'm the manager of the Housing Choice Voucher Program, which is under the Rental Assistance Division in the Department of Housing and Community Services. I have been before you a couple of times recently regarding the same topic. And today, I'm glad to be able to present a draft of our administrative plan changes that will be required under the housing opportunity for Housing Opportunity through Modernization Act of 2016. And let me just take one moment to bring up the slides. Thank you for your patience with that. So I am going to start the presentation with an overview again of the Housing Choice Voucher Program just as background. This is the primary rental assistance program that is funded through the Department of Housing and Urban Development. These vouchers, the Section 8 Housing Choice Voucher Program, are administered by local public housing authorities, which are all operating under a contract with HUD. And the Santa Rosa Housing Authority is contracted to administer 1925 housing choice vouchers. The regulations that guide the Housing Choice Voucher Program are found under the Code of Federal Regulations Part 24. And additional guidance appears in public and Indian housing or PIH notices. Those come out throughout the years. And the discretionary policies for the Housing Choice Voucher Program, there are some, not many, but there are some discretionary policies. And where those policies appear are in the local administrative plan, which is the document that we are substantially revising and presenting to in draft form today. The administrative plan must be adopted by the Housing Authority Board of Commissioners at a public meeting. And changes to the administrative plan sometimes are only affecting certain parts of the administrative plan or certain policies may be focused as changes in the administrative plan Previous times that I've been before you in the recent years have been just for specific policy changes regarding the administrative plan, and they don't affect the entire admin plan. But in this case, the regulation changes that are required under HOTMA, which is the Housing Opportunity Through Modernization Act of 2016, will affect the entire administrative plan. When I was here in September of last year and October of last year, we did not have as much information about the HOTMA implementation as we do now. And now that we have both the implementing regulations that came out in late September, they've also been revised as recently as early February. So these regulations we anticipate we will continue to make adjustments to the administrative plan. I mentioned that in my previous study sessions that we would hope to come to you with a full draft at this time of year and then anticipate that we will continue to make changes and adjustments to the plan, to the admin plan document as the year goes on to make sure that we're complying with the changing implementing regulations for HOTMA. So what we have, one of the things that we anticipated, but that changed from our previous study sessions, is that we were anticipating that because of the degree to which the changes are substantial in the admin plan and the uncertain date where those changes would take effect, we anticipated, and I said in previous presentations that we might have a document that includes pre-HOTMA and post-HOTMA policies. But luckily, we don't have to do that because that document would be very lengthy and it would also be very confusing. So we have presented as part of our annual plan process the draft of the administrative plan changes which we anticipate. If the plan is adopted, we'll become effective on July 1 of 2024, which coincides with the beginning of our fiscal year. I mentioned that, and this means that the current administrative plan will remain in effect until that date. HUD has previously said that all of the HOTMA changes have to occur at the same time. And so our target date for that change will be July 1, which coincides with the beginning of our fiscal year. The last changes that we did make to the current administrative plan occurred in October. But as I mentioned is often the case, those changes were only related to one section of the administrative plan. So they were moderate. They memorialized the procedures that we adopted for an electronic waiting list. So that was only in one chapter of the administrative plan. That was the last time that we discussed the administrative plan as a body and the last time that you adopted changes to that document. The HOTMA changes are substantial, as we've mentioned throughout our study sessions, about this upcoming change. And they will require near total replacement of four chapters of the current administrative plan plus additional language revisions throughout the document. All of the changes to administrative plan policies require the opportunity for public input. And changes as significant as these must be presented as part of the annual public housing agency plan process. Whether or not the agency has any discretion in the policy changes. So we are presenting the administrative plan as part of our annual PHA plan process. The administrative plan is currently available for public comment. It's posted on our website. It's also available in the lobby of our offices. And it is included as part of your packet today for this study session. So our intention with this study session is to review the proposed changes in as much detail as is feasible for this forum. And gather feedback from the commissioners and the public where there is policy discretion in the administrative plan. We will then return in March with the administrative plan incorporated into the annual PHA plan with the intention to approve the plan for adoption effective July 1 of 2024. So for the sake of time in this presentation, I will be focusing more of my discussion on the areas where there is housing authority discretion. And the documents provided as part of your agenda packet do follow the same pattern. There is a summary of all of the changes that are in the administrative plan draft as well as an outline of the discretionary policy decisions that had released in September of 2023 along with implementing regulations for the program. We've also included a full red line version of the document, which if you have reviewed, you know, is long. So I will keep this slide up as I go through the changes that I'm going to be discussing, but I did not include what I'm discussing as part of the slides just because they would be very wordy and I think it's more effective if I speak to you about these. So we are gonna start with some highlights that HUD has given to us to communicate to the public regarding some of the highlights and the good things about the HOTMA legislation changes for the program. So one of them is that there will be fewer and interim reexaminations. So by introducing a 10% threshold for conducting interim reexaminations, which I'll get into in more detail later, also in most cases, we are going to be required that we do not process interim reexaminations for increases in earned income, as long as it's under a certain threshold, this allows families to keep more of their earned income throughout the year between their annual recertifications. So overall, we're anticipating that there will be a fewer number of interim reexaminations of income. HOTMA also allows for some streamlined verifications and it eliminates the requirement for families to sign consent forms annually and decreases the frequency with which PHAs are required to review certain HUD reports regarding family income and employment. HOTMA increases the standard deduction for families with a head, co-head, or spouse who is elderly or a person with a disability and it implements inflationary adjustments to the standard deductions. This is the first time that has happened since the program's inception. HOTMA also raises the threshold for claiming medical and disability expenses from 3% to 10%, but does allow for hardship relief when those changes impede a family's ability to pay rent. HOTMA raises the imputed asset threshold from $5,000 to $50,000, which incentivizes families to build wealth without imputing income on those assets and it allows for family self-certification assets of assets under $50,000. And HOTMA, for the first time in the program's history, introduces an asset limit to the Housing Choice Voucher Program, which makes families ineligible for assistance if they have assets over $100,000 or if they own real property suitable for their own occupancy. However, HOTMA also requires that retirement and educational savings account are excluded from net family assets, which also provides administrative relief to PHAs by allowing us to stop verifying and calculating income from these types of assets. So now I'll begin a review of the changes to the administrative plan in the order in which they appear in the plan and you can refer to the summary of changes over the actual red line document as I go along. So in chapters one and two, these cover an overview and description of the voucher program and of the fair housing requirements we follow. These are minor changes in these program, in these chapters, they're not related to HOTMA and it's mainly to update the regulatory references because many of the citations have changed as a result of the change in the legislation. Chapter three covers eligibility for the program and this is the first place where significant HOTMA related changes and other changes related to new or updated legislation appear. So many of the changes in this chapter are not where we have discretion to make any different decisions than what HUD has prescribed. Edits to this chapter have been made for clarity and policies regarding definitions of various household members. These are places where we do have some discretion. We have removed a reference to common law marriage in the definition of spouse because common law marriage is not recognized in the state of California. To simplify the verification process regarding various household member statuses, we have revised the definitions of absent students and other absent household members to be more consistent with each other and more consistent with HUD recommendations. HOTMA also changed the requirements for when and how often a family provides consent for their information to be verified. And in this, we are recommending a policy that is consistent with our current policy, which is that if a family refuses to provide consent or revokes their consent to verify their income information during the eligibility determination process that they will be denied assistance. HUD has also updated its recommendations regarding criminal background screening in eligibility and these policies in the chapter have been revised to concur with those recommendations. We have revised the definition of currently engaged in criminal activity from six months to three months regarding the use of illegal drugs. And we have revised the definition of evidence of criminal activity and previous behavior in assisted housing to a look back period from five years to three years. And again, that's consistent with HUD recommendations regarding those policies. So I'm going to pause between chapters to see if there's any questions because there is a lot of information. Okay, I saw a commissioner Downey first, please. Is there a 10% allowance for disabled related expenses that can be factored in? I can tell you from my own experience, that feels really low. And I don't know if this is their policy or your policy, but is there any way that that deduction can be increased? Because quite frankly, it's very expensive to be disabled. I thank you for that question. And that is an example of where we do not have discretion over the threshold change. So hot mud does change the threshold for the medical expense deduction. Currently, if you're an eligible household to qualify for those expenses to be deducted from your annual income, the threshold over which the spending occurs is 3%. Hot mud is raising that to 10%. So it will impact families who qualify for that deduction because less of the income or less of the expenses will be permitted to be deducted from annual income. However, at the same time, hot mud is introducing new regulations regarding requesting hardship exemption from those rules. So I will get into those in more detail later in the chapter or later in the presentation, because those policies appear in a different chapter. Yes, Commissioner Friedman. Half of the states by state law cannabis products are legal, but by federal law, they're still illegal. And I'm wondering how long, if at all, people would be ineligible for housing assistance through this program if they have any convictions by federal law for cannabis consumption. I'm sorry, you're speaking specifically about cannabis. Okay, so that, right, right. So that has been a previous point of conflict where there are states that recognize cannabis for medical or recreational use and that has not changed at the federal level. So hot mud does not speak to cannabis specifically and we will continue to follow the federal regulations as required. Well, the look back period, we are becoming, there's more flexibility with that now. So it had previously been five years and now it will be three years. So, but it is also not a place where necessarily the decision would have to be to deny assistance. It does depend on the circumstances of the particular criminal act. So the PHA does, well, the family always has a right to appeal a denial decision and there are circumstances that we can consider. If, for example, someone was using that as a medical or recreational use that was allowed under state law. So there is some place where there's discretion, yeah. Yes. Any other questions about chapters three? Seeing none, proceed. Okay, thank you. It's okay. Okay, so chapter four, which is related to the wait list and tenant screening was most recently updated in October and it does not contain any HOMA related changes so we don't have to talk about it. Chapter five discusses the policies and procedures related to briefing new families as they come on to the program. This chapter does not contain any HOMA related changes. However, we have updated language in this chapter to include policies that memorialize the practice of remote briefing options, which were introduced during the COVID-19 pandemic but which have always existed as a reasonable accommodation. We've also added language reinforcing policies, practices and the PHA's commitment to equal access to the program and so far as language access and disability related needs for accommodations. And we have updated for the purposes of clarity the bedroom size determinations describing both the minimum and the maximum number of household members for each bedroom size. There is no policy change here. We just wanted to make sure that the current language in the plan was more clear. And moving on to chapter six, this is the first chapter that is largely replaced under HOMA. This chapter describes the income and subsidy determinations in the program. And many of these changes are required and do not include any discretionary policy decisions. However, we have brought into chapter six the same clarifications and simplifications regarding absent household members that I discussed as part of chapter three regarding eligibility of those household members. We've brought those into chapter six so that there's consistency between the policies. We have also updated the definitions, the same definitions in chapter six as we did in chapter three. We've added some clarity and additional verification steps to the policies regarding the relatively unusual situation when a caretaker for children needs to be appointed after the head of household leaves and no one over the age of 18 or older is a remaining family member. And there are four policy decisions which are outlined in the summary of the discretionary policy decision that's in your packet. Four of those policy decisions appear here in this chapter six. So I'll go through these one by one. We've made recommendations, we've made policy recommendations and we've made those based on best practice. The decision that is in the best interest of the participating family and what is least burdensome for families and for staff, that those were sort of our guiding principles as we were going through making these policy recommendations. So the first is related, Commissioner Downey, to your previous question which is the hardship exemptions for health and medical care expenses under the general relief category. HATMA increases the threshold for claiming medical expenses from 3% of annual income to 10% of annual income but also allows families that qualify to claim these expenses to request a hardship exemption for unreimbursed health, medical, attendant care and auxiliary apparatus expenses when the eligible expenses exceed 5% of annual income. PHAs must establish policies describing what constitutes a hardship and whether the hardship exemptions can be extended. So we are recommending a policy that defines a hardship as a documentable decrease in income or increase in actual expenses that are impeding a family's ability to pay rent. We are recommending also that extensions to the hardship period will be considered on a case by case basis. The second policy decision is also related to hardship exemptions for health and medical care expenses under the phased in relief category. HATMA requires that the increase in the expense threshold from 3% to 10% is phased in over two years for eligible participating families who are already receiving the deduction as of January 1st of 2024. Participating families who are currently living in public housing but moving to the voucher program are eligible for their phased in relief period to continue between programs if the PHA allows it. We are recommending that all families being newly admitted to the program here in Santa Rosa follow the same rules. Therefore, we are not recommending that we adopt the policy that the phased in relief continue when you're transferring between public housing and voucher program. This would be more feasible if we had public housing here in Santa Rosa, but we don't. So that would require us to have that phased in information from the previous housing authority and there's a chance that we just won't do it right. So we would like to recommend that we start out every new participant on the program under the same rules. The third discretionary policy in chapter six is related to the hardship exemption to continue a childcare expense deduction. Pre-Hotma eligibility for deducting childcare expenses required that the family needed childcare to go to work or to go to school. Hotma allows for a hardship exemption for families who are already receiving the deduction to continue receiving it if their circumstances change and they still need childcare even when they are not working or in school. PHAs must establish written policies about what qualifies as a hardship and establish whether or not extensions to this hardship period may be granted. We are recommending that a policy requiring a documentable inability to pay rent exists and that it is a result of the childcare expense ending. We are recommending consideration of extensions of this on a case-by-case basis. The fourth discretionary policy decision in chapter six is related to permissive deductions. PHAs are required to make certain deductions from the family's annual income, such as allowances for families with dependents or elderly heads of household. PHAs are also allowed under Hotma to make additional optional permissive deductions to annual income if they are related to encouraging self-sufficiency or have another economic purpose. Since they are optional, HUD makes clear that the PHA will not receive any additional funding as a result of higher rental assistance costs resulting from these permissive deductions. We are recommending one permissive deduction adopting here in Santa Rosa for families participating in guaranteed income programs. These amounts are already excluded by the state of California for families who are receiving welfare assistance, and this allows for consistency between these programs. This is also aligned with HUD's intention that additional deductions are for the purpose of an economic purpose or self-sufficiency. That is the chapter six pause that I will take now. You have questions about what we've discussed in chapter six. Any questions, Jeff? Thank you, it's a very complicated process. So as we saw through COVID times, there's 19, 25 vouchers. However, people weren't working, and so their income went down. So the amount of money that was going through the voucher program, even though the number of vouchers didn't change, went up. So do you take into account that you're not gonna put out all 19, 25 because of that possibility, or is the 19, 25 represent the amount that is out and there's some headroom on top of that? How does the authority take care of making sure that you have in balance not only the number of vouchers, but don't exceed the dollar limit of the vouchers? Yes, thank you. That's an excellent question, and you're correct. We are not currently leasing all of the vouchers under our contract, and the reason is because we're spending all of our money on approximately 94% of the vouchers that we have in our contract, and it's because of the costs of the rental assistance. Some of that is still related to increases in the per unit cost that we're resulting from the pandemic. Some of it is also just related to that rents are high, and so that increases our per unit cost over time. The specific permissive deduction related to guaranteed income programs, we do not anticipate we'll make any difference really in the amount that we are spending or for our per unit cost because the number of families that we anticipate participating in programs like that is very small. There is right now in Sonoma County, one pilot program, and I believe we have three families who are participating. We are currently counting the income that they're getting from the guaranteed income program because we're required to under the pre-HATMA rules. We did ask for a waiver of that requirement, and it was denied, and the reason that it was denied was because HATMA was coming, and we could decide to, at the local level, exclude that income for participants in those programs. So because we only have a very small number of families who are currently participating in a program like that, we don't anticipate that that will make a big enough difference overall to consider not allowing that deduction. The deduction for guaranteed income programs is, we think, important because when families are participating in those studies, it does, it impacts the result of the study. Those are usually research studies. Those are usually funded by the government. The state is currently funding the one that is going on right now, and because it skews the data of the research study, we wanted to try to cooperate as best as we can with the goal of those programs, which is to study the concept of guaranteed basic income. It's also consistent with the way that the state of California has adopted exclusions related to those programs in their own welfare programs. So another follow-up question, kind of still staying in the weeds here. So the Housing Authority puts out, this is what we think a market rent is for a studio, a one-bedroom, two-bedroom, and the tenant pays 30% of their income toward that rent, and then the rest is picked up as from the voucher and the housing choice voucher. So to the extent that income goes down, the amount of housing choice voucher goes up to again get to the dollar amount for the stipulated rents. How often are those rents reviewed and are those rents done at the local level or are they stipulated at HUD's level? I hope it's the former and not the latter. It's a combination. So the fair market rents are determined by HUD. Those come out, they're effective for October 1st of every year. And from the fair market rent amounts, the local level, the local Housing Authority has the discretion to adjust the fair market rents to between 90% and 110% of the fair market rent for each bedroom size based on their own local needs in so far as what the actual rents look like. So we have for the most part always brought those up, brought our payment standards up to be 110% of the fair market rents. Over the last year, when the numbers came out, they were really finally aligned for the most part with what rents we were actually experiencing. Not for all bedroom sizes. There are some bedroom sizes that because of just general impact and demand in the community, those rents tend to be higher than some others. So it's not a perfect system, but we do have a discretion there and Hotma does not change that. Okay, thank you. Mr. Downey. Looking at an apartment that was two bedrooms and they were charging $4,000 a month. It was not that nice. And the rumor was that the jurisdiction of Santa Rosa is trying to entice San Francisco will allow people to come into our community and rent these over the apartments. And I'm curious. I know that rent control is a profanity. I don't know where we went with rent stabilization or that was a partial, you know, infinite profanity. But is there any room to try and get ahead of this so that we're not priced out of option for people who clearly are not able to afford this? So those policies, rent control, rent stabilization, they're not under the purview of the voucher program. That would be at the state or local level and it would not be the housing authorities purview. It would be the city council. So I don't have any information about that question. I'm sorry. Mr. County. Yeah, I have a question on the hardship exemption. Now, that's determined during the annual recertification so it would affect the amount future rent would be for the following year. It's not something that's, you know, a month to month determination. That's correct. Mr. Smileft, any other questions? Hearing none. Rebecca, I'm totally amazed how you got through that. So well, you presented it wonderful. I appreciate that. I'm only halfway there. I was hoping you weren't gonna say that. But we don't have to go into as much detail in every chapter. So, but chapter seven has been substantially revised with required changes under HOTMA. And again, I will be focusing on the places where we do have some discretion. So we are making recommendations as described in your discretionary policy decision summary item number 11. We are recommending that at this time that we do not accept family's income verification from other federal income assistance programs. This is an option under HOTMA, but we feel that at least in the early adoption stage, we need to make sure that our staff and our families understand the new rules as they apply to housing authorities. So it would not be a good idea to use the income certification from another type of program. As described in the discretionary policy decision summary item number 12, we will adopt the option to minimize the use of HUD's enterprise income verification or EIV report where possible. Under HOTMA, we are also required to describe how we use the other reports that are made available through the EIV system. And our recommended policy is to review these reports out of family's annual income, but not more frequently unless it is necessary for the investigation of a discrepancy. Also appearing in chapter seven, we recommend adopting a streamlined verification process when 90% or more of a family's income is from fixed sources. This was a pre-HOTMA option that we did not adopt but are considering now so that we can take advantage of available efficiencies where it is reasonable to do so. Families who are receiving Social Security or SSI fall into this category and it can be already burdensome to them to obtain verification of these payments when we as the PHA request it. So this change will benefit families and staff and reduce administrative burden for both. The final discretionary item in chapter seven is described in your discretionary policy decision summary as item number one. Under HOTMA, PHAs may accept a family's self-certification of their net family assets equal to or less than $50,000. If a PHA chooses not to adopt this option, they must continue to verify all assets regardless of value under HUD's verification hierarchy. This is the current practice and can be very burdensome for families and for staff, especially when the assets carry a small value and do not generate any income. Adopting self-certification practices will relieve families who have assets under $50,000 of the obligation to produce asset verification unless it is necessary as part of the income verification process or if the PHA has reason to believe that the value of an asset is being underestimated by a family. Full verification of assets will be required every three years regardless of value. Similarly, we are recommending the acceptance of a family's self-certification that they do not own any real property. Ownership of real property suitable for a family's occupancy makes a family ineligible under HOTMA. But this is a rare circumstance and the majority of families on the program do not own property. So self-certification makes the most logical sense for this item. Okay, that covers chapter seven. Are there questions there? Sure, I have a question. So the income verification, is there a certification on that form that the tenant verifies this and if it's proven to be incorrect that it could be dropped from the program? Yes, there is a statement about making false statements, under penalty of perjury, et cetera. That language is actually in the administrative plan. Perfect, thank you. Any other questions? Go ahead, Rebecca. Thank you. So chapter eight is also being substantially revised in this draft of the administrative plan. This chapter discusses inspections and under the approximately the same timeline as HOTMA requirements are rolling out, HUD has also required the adoption of new inspection standards. The current inspection standards are known as the housing quality standards and new standards are called the national standards for the inspection of real estate or Inspire. The purpose of Inspire is to align inspection standards across all HUD programs. There is no policy discretion within chapter eight, but it is replacing all of the housing quality standards language with the Inspire standards and the protocols. We have also revised language in this chapter to clarify that we are currently following HUD's inspection frequency standards of biennial inspections that's every other year. And we've added language and policies regarding remote video inspections, which may be deployed during times of public health or other emergency. And I mentioned in our previous study sessions that this change was also coming, that it was not related specifically to HOTMA, but is following roughly the same timeline. I'll also remind commissioners that the Santa Rosa Housing Authority has been a pilot agency for Inspire standards for about four to five years now. So we are quite familiar with the standards. This part of the community is already familiar with because we've been using the Inspire standards in parallel with the HQS standards for the last several years as a pilot agency. So the language is changing significantly, but in terms of our practices, there isn't going to be much of a change. So that covers chapter eight and are there questions there? So since we've been using the Inspire standards, have you had to do the remote inspection at all? We have not. We included the language about remote inspections so that we had the option if we should have another type of emergency that it is in the best interest of the families and of the staff that we don't actually enter the unit, whether that's a public health emergency or another type of emergency. During COVID, we adopted the waiver to just bypass doing inspections. That was the way that we decided to handle that. Instead of trying to implement the video inspections because we just didn't have the technology to be able to do that. Yeah, that's what I was really curious about is how that went. It seems like COVID is exactly what that was written for. So how should it work? Had we done it? HUD has flushed out the requirements more now. And so essentially what it requires is that you establish a proxy. So typically that would be the owner of the property. That person does need to have a device of their own, an iPhone or an Android phone that has video capability to essentially walk through on a video call with the inspector who's at the office. Thanks. Sure. Okay, moving on to chapter nine. This covers our general leasing policies and has actually relatively few changes. Mostly we're updating references to inspections and the inspire language. And we're clarifying language in existing policies. We always take the opportunity, if we can, to clean up language to make sure it makes the most sense to the most people. This chapter also includes updates to regulatory language for households who are protected under the Violence Against Women Act, otherwise known as VAWA, as required under VAWA. Chapter 10 discusses moving with continued assistance, including portability between jurisdictions. As such, there are updates to the language that is necessary for clarity and to memorialize current practices that became mandatory under previous HUD notices, but were not fully discussed in the admin plan. And chapter 11 discusses reexaminations. And this is another chapter that has essentially been fully rewritten under HOTMA. I will focus my discussion on what we have on the places where we have policy discretion as I have been doing throughout the rest of the presentation. So referring to the discretionary policy decisions under HOTMA, your summary there, this is item number seven, regarding interim reexaminations for decreases in adjusted income. HUD is allowing PHAs to establish a threshold from which it will be determined if an interim reexamination will be completed for decreases in income. We are recommending the adoption of a policy stating that we will not conduct an interim reexamination for decreases in income that are less than 10% of the family's adjusted income. This will reduce the number of interim reexaminations that are completed overall, and the impact to families will be offset by the HOTMA requirement that PHAs do not complete interim reexaminations for increases in earned income, as well as our other recommendations in the next categories, which are intended to allow families to retain more of their interim income increases without paying higher rents between their annual re-certifications. Item number eight on your list of discretionary policy decisions, HUD is allowing PHAs to choose not to conduct interim reexaminations when an increase in income is reported within three months of their next annual reexamination. So our recommendation is to adopt this policy and to limit the number of interim reexaminations for increases in earned income. There are certain instances where an interim will still be required, such as when the increase is over 10% of annual income and is not related to earned income. Item number nine of the discretionary policy decision summary also relates to interim reexaminations and a family's obligation to report their income changes. Due to the extensive changes throughout the rest of the program, we are recommending that at this time, we do not change our current practice of requiring families to report all income and household changes within 10 days of their occurrence. HATMA also requires that PHAs adopt or continue policies regarding the effective dates of interim reexaminations when a family has failed to report income changes in a timely manner. We are recommending that we continue our current practice to not apply changes retroactively when a family's failure to report an income change results in a decrease in their rent. Retroactive changes can be confusing to owners and to families, and we are recommending avoiding them where possible. So, pausing there for questions regarding chapter 11. Am I right? Okay. Am I right? Any questions? No. Commissioner Frug. Yeah, I'm wondering if the reason for, if I understood correctly, decreases in adjusted income which would result in an adjusted amount of the family share of rent, which now must be at least 10% of the family's income. If the reasoning for that is to minimize the housing authorities workload or if there's other reasoning behind that? Yes, that's part of it to reduce the administrative burden, but also because we believe that in our other policy recommendations and in HUD's requirements to allow families to keep more of their increases in income that those two things will offset each other. That's what we're anticipating will happen in practice. So if that same family experiences an increase in income shortly after a decrease in income, we won't have to count the new income or the increased income either. So it goes in both directions. Any other questions? Commissioner Owens. Couple of questions. So at what point, if one of the tenants happens in the household to get a good raise, are they dropped from the program to see how much can their income go up before they're no longer qualifying? That's a great question. And that is not changing. That policy isn't changing. And the answer is that when 30% of the families adjusted annual or adjusted income equals the full rent and utilities. So essentially on this program, when you can afford to pay the entire rent, that's when you graduate from the program and there is 180 day grace period. So if anything changes, if the great new job doesn't last or some other circumstances come up and the income is lost, then the family has 180 days to report that change to us so that we can bring them back to receiving assistance if that's what is required as part of that interim or examination. Thank you. And then again, that would be based upon 30% of their income being applied toward rent and plus utilities. And then another question is, so a tenant will provide their income, they certified that's their income, how is that verified? And what sampling size does the housing authority do? Yes, the verifications, the requirements about verifications are changing in certain circumstances. I mentioned one previously, but essentially we will continue to verify all income information either through directly through the third party. So we send a verification request to the, if it's an employer or other income source, that will continue to be the standard by which we verify income. Hotmail introduces a little bit more flexibility about verification of assets and that's where that self-certification comes in. So there's no, do you work with Social Security Office? Because all that has to be reported if it's W2 income. Yes, where that information appears is typically in the enterprise income verification system that HUD has created. So there is a database of social security information, SSI, unemployment wages, and sometimes state unemployment information. In a database that we can access and that we do access every time a family has an income recertification. Perfect, thank you very much. Any other questions? Go ahead, Jeremy. I was gonna save it, but that enterprise database you were just talking about, was that new as part of these changes or is this a legacy system that's been in place? Yeah, that's a good question. It has been around since I think about 2012. So we've been using it for a while. What Hotmail does is gives us a little bit more flexibility about how often we have to access it. Right now, we're required to do a full verification through EIV anytime that there is an interim change. We won't have to do that anymore, partly because we won't be doing as many interim recertifications. The focus under Hotmail is really going back to annual certifications of income and that's where we will continue to access the EIV reports. And as I mentioned, we still have the option if we have reason to believe that there's something incorrect about what is being reported to us, we can always go and check that system. Okay, so EIV is the big enterprise database that you're talking about? Yes. Okay, thanks. Go ahead. Okay, so Chapter 12 covers our policies regarding terminations from the program. It does include some changes in this draft, but very few where there is flexibility. For consistency with the policies regarding admissions to the program, we have revised the look back period for certain definitions related to criminal or drug related activity to align with the Department of Justice and HUD recommendations. We've also revised some language in this chapter for clarity and consistency with other HUD recommendations. And we've rewritten the policy regarding termination of assistance for insufficient funding to align with the new Hotmail policies. So a termination from the program for insufficient funding would happen in the event that the Housing Authority has run out of money that Congress is not giving us any more money to continue to sustain our program and we have to cut families from the program that has never happened in my tenure, but we do have policies about it so that we're ready in case that ever does happen. Our current policy, the pre-Hotmail policy, the first households that would be terminated for insufficient funding are those who have assets over $100,000, but that's no longer necessary because Hotmail is introducing an asset limit. So we're eliminating that and we're rewriting that to align with the HUD recommendations, which is essentially that the people who are on special voucher programs because those households tend to be more vulnerable, those are the households that will remain or they're the last to be terminated from the program. So that is all that I have to say about chapter 12. Are there questions there? I'll ask one more time any questions from commissioners? Go ahead, Mr. Fadah. In that unlikely circumstance that funding gets cut and people have to be terminated from our program, who would be first to get terminated? The recommendation is that the people who have been on the program for the least amount of time are the first to be terminated. And so it would not be related to their assets or income? No, not in this circumstance. This policy is strictly related to if the housing authority does not have funding to continue to sustain all of the households on the program. So it'll probably never come up, hopefully. Yeah, thank you. Hearing none. So then moving on to chapter 13. This discusses the PHA relationship and policies regarding owners participating in the program. This chapter does not include discretionary policy changes under HATMA. However, we have revised references to the inspection standards and we have clarified an added language regarding our current practice or practices verifying home ownership information and an owner's eligibility to participate in the program. Chapter 14 is titled Program Integrity. It does not include very many changes, but there is one discretionary policy under HATMA. This change is referenced in item six under your discretionary policy decisions document. And in this policy or under HATMA, rather, HUD has established a definition of a de minimis error as a PHA error in calculating family income where the deviation from the correct income is $30 or less per month. So that's a new definition that's being added to the regulation. HUD is allowing PHAs to still be considered in good standing if this de minimis error occurs, but when the family overpaid their rent as a result, the PHA must reimburse the family. The policy decision here relates to how the PHA will reimburse the family. And our recommendation is that we reimburse the family directly. As I've mentioned previously, retroactive changes can be very complicated and confusing. So this is another way that we can minimize that and also provide immediate relief to the family for the burden of the overpayment. Chapter 15 covers special housing types. It has been reorganized, but no significant policy changes are found in this chapter. We have updated regulatory references as needed for Inspire, VAWA, and HATMA. There are no discretionary policy changes recommended in this chapter. Chapter 16 discusses program administration. Again, there are no discretionary policy changes here. Just updates to the language and references, mostly for clarity, and to ensure that all current HUD regulations are also outlined and referenced in the policies. Chapter 17 discusses project-based vouchers. The changes in this chapter are not discretionary, but the only updates are to the inspection standards references and other language changes for clarity. Chapter 18, this is where it gets a little bit interesting, does not appear in full in our administrative plan because it references a program that we do not administer. But because reordering and renumbering the chapters would make cross-references throughout the document very difficult to follow, we've elected to keep reference to chapter 18 and not renumber the chapters. Chapter 19 is a discussion of special-purpose vouchers. This is a new chapter to our administrative plan. Previous versions of the plan included policies regarding the use of special-purpose vouchers. In our case, that's only HUD VASH, the Veterans Affairs Supportive Housing Program. The policies regarding the special-purpose vouchers previously appeared in the chapters of the administrative plan where there were deviations from the normal Housing Choice Voucher Program rules, but for clarity and so that we can offer a more full discussion of the special-purpose voucher, we are taking that out and adding it as its own chapter. Let's see. There are no policy changes in the chapter. We've just added more language discussing those special-purpose vouchers more thoroughly. The glossary has been revised to include all of the new and changed definitions under HOTMA, new and revised acronyms, and the addition of definitions regarding remote participation in inspections, as well as remote participation in interviews with families if that is necessary as a result of an emergency. And the temporary policy supplement, which covers the Emergency Housing Voucher Program, was previously included in the administrative plan as chapter 19. It has been moved to the end of the administrative plan, but no changes have been made to any of the policies. So, that concludes almost my presentation. That concludes the notes that I've brought with me. We'll go back to the slides, but I have covered most of this information. So, the Housing Quality Standards Inspections, those were covered in chapter eight, those are being replaced. Another related change to under HOTMA and occurring at the same time as HOTMA is that our reporting systems are changing. So, the where we report and how we report our family data and our financial data are each going, those are two separate systems currently, and those are going to be replaced and merged into a new single system. We are following that transition as best as we can. We are ready to start testing in the new system just as soon as HUD is ready to let us start testing in the new system. As I mentioned in the beginning of the presentation, the HOTMA transition is essentially all or nothing. So, once we adopt our HOTMA rules, we have to adopt them all at the same time. And under the legislation, this transition must be complete no later than December 31st of this year. We are hoping to be able to follow a timeline where we transition to the HOTMA rules effective July 1st, but this does require the new reporting system, the new financial data system to be up and running and for us to be able to participate in those. If those aren't ready for us, then by July one, then we can't adopt these rules by July one. We have to wait until HUD is ready for us to submit our data that way. So, at this moment, we are anticipating that the planned effective transition date for our agency will be July 1st, but that could change if we don't get access soon to the ability to test in those new systems. The administrative plan changes, as I mentioned, do constitute a significant amendment to our annual PHA plan. And as such, the admin plan and the annual PHA plan are both currently open for public comment. So if anyone listening to this presentation at home has comments or feedback about the policies that we have discussed today, we'll be incorporating that and bringing all of that information back to our next meeting. Additional changes, as we've mentioned throughout the presentation, just making sure in our admin plan that we're referencing all of the most current legislation, not only the Code of Federal Regulations, but all of the current notices and final rules that affect our program. We also, as I mentioned, always try to make sure that the language is easily accessible. It is pretty heavy and technical, but we try to make it as user-friendly as possible. So an opportunity to rewrite, we will try to make sure it's concise. So our next plan to come back before you is with any changes that are recommended as part of the public comment process or by you as the Board of Commissioners. And we will bring back the full administrative plan at the March 25th meeting. That's also when we'll be bringing the Public Housing Agency plan. And if we, the plan that is adopted at that time provided that we're still on track with HUD's timeline, we will be adopting the new administrative plan with an effective date of July 1 and we'll be adopting it at the March meeting. And that is actually the conclusion now. My presentation, thank you. Even though I tried to give you a break midway, you powered through it. It was amazing. And I think it was 600 pages in total that you had to go through. 626-ish. Not that you were counting. 630, yeah. Okay, we'll move on to, you have a question? I didn't know that, go ahead. Just on the last few slides you ran through there, that, so that website or that, I think that's what I was thinking about. I knew there was some sort of IT system or something that we were waiting on and it was on HUD's. And so that's what you're talking about here, this family data. And so that's different than the EIV. That is different than EIV, yes. There are two systems right now. One is called the Public Housing Information Center. That's where we submit all of our family information. So who is participating in the program, what their income is, what address they live at. And then we have a separate system called the Voucher Management System where we report all of our financial information. So those two separate systems are merging into one system called the Housing Information Portal. That is not yet ready for us to be testing, but we are ready for that, whenever they are ready for us. Yeah, do you guys think that, and I guess my second question is about the administrative burden for the department. This maybe being one of them, I assume this portal was supposed to make things easier for you guys. And do you see it sort of playing out that way with the changes? Are they more less of a burden, more less cost to the department? What do you think on that? Well, I'll give you my opinion, which is that this will be more difficult to administer, especially in the beginning, as we're learning, as the staff is learning all of the new rules, because it really does upend the way that we've been doing business for the last, since 1983, I think, when the program first emerged. So there's a lot that we need to learn. We are in the process of learning it, going through trainings and getting ready for this transition. But I think, I hope that after a year or so of operating under the new rules, once we all have our wits about us in terms of how it's actually playing out, that overall the administration of the program won't change that much. Appreciate it. Thanks. Commissioner Downing? Good to, how much is all this gonna cost to make these really phenomenal program changes? And is this something that we're having to pay for? Or is there an outside agency that's gonna help buffer some of the costs associated with such a massive overhaul? I appreciate the question. And we do not have any control over the amount of funding that we receive from HUD to administer the program. And the amount of money that we receive is not increasing as a result of this legislation change. So we will do this with the money that we have. Commissioner, I was just curious, how big is the staff? I mean, we just see usually three people here, I'm just curious. Yes, sorry, I had to look to Kate who's the administrative services officer who sometimes has that in her head better than me. Our staff is currently 13 full-time equivalents. So we have the bulk of those folks are the technicians who are doing the direct service to the families, going out and doing the inspections and also doing all of the eligibility certifications. Have you increased it in the last year? Are they kind of like steady? I didn't get the impression from Megan once that you're getting much help. No, the last time that we augmented the staff was for a limited term position related to the emergency housing voucher program. But we have not added any staff and we don't anticipate doing that as related to HOTMA. Okay, one last time, any questions? Commissioner Conti. Yes, on the chapter 18 program that we don't participate in, what program is that? That's a great question. That's the rental assistance demonstration and if you are an agency that has public housing, you can convert your public housing into project-based voucher housing under the rental assistance demonstration program. So we don't have that program because we have never had public housing. Okay, hearing no other questions, we'll move on an open public comment on item 4.1. Chair LePenna, it appears that we have no in-person public comments for this item. Okay, we'll move on to item 5, which is non-agenda public comments. And Chair LePenna, once again, it appears that we have no public comments in person for item 5. Thank you. Item 6, approval of the minutes. We have minutes from the January 22nd, 2024 meeting. Are there any changes to those minutes? Hearing none, they're approved and prepared. We'll move on to item 7. Chair Pershing and Commissioner reports. Any reports? No reports. We'll move on to item 8. Any committee reports? Hearing none, we'll move on to the next agenda item, which is item 9. The executive director report, and we'll hear from Kate Goldfein. Yes, good afternoon, Chair, Vice Chair, and commissioners. I'm Kate Goldfein, Administrative Services Officer for Housing and Community Services, filling in for Megan Basinger today. Bassenger, sorry. So I just have a few quick things. One thing I wanna note is that the current attorney that is serving the housing authority is named Ethan Walsh, and he is assisting us via Zoom today, which is why you didn't see anybody here at the table. And he, oh, there he is. And for the foreseeable future, he will be our attorney and has extensive experience in housing, and so we're very glad to have him. I also wanted to briefly introduce our new administrative secretary for our department, and who will be the housing authorities recording secretary going forward will be Cameron Gordon, who's sitting next to Steve there. And also, and I'm sorry if I missed this, but Ashley Paul is also a staff member who will be assisting the housing authority going forward. This is because Steve has transferred to a new position, so he's gonna be doing some training, and then you will get emails and correspondence and see these new faces at the meeting going forward. And so we are very, very grateful to Steve for all of his work with the housing authority and for training our new staff. And then finally, just a really quick thing. So I was at a meeting today where our city clerk reminded me that as housing authority commissioners, you are required to complete and submit a Form 700 as part of the Fair Political Practices Commission. And so you all should have received emails about that. If you have any questions about that, you can contact me, you can email me or call me. It might have gone to your srcity.org email address, so make sure that you're checking that. If you haven't received it, let me know I can assist someone and I can connect you with our city clerk's office who can assist more if you need more assistance. And so finally then, we also have our pending development pipeline, which is part of the agenda packet you have and that concludes my remarks. Item 10, consent items. Any consent items on the agenda? Hearing none. Item 11, any reports or notes? Hearing none. Committee's adjourned.