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Home My WebLink About2020 PHA Annual Plan FinalPHA Annual Plan for FY 2020 County of Hawaii Office of Housing and Community Development 1990 Kino'oIc Street, Suite 102 • Hilo, Hawaii 96720 • (808) 961-8379 • Fax (808) 961-8685 Existing Housing: (808) 959-4642 • Fax (808) 959-9308 Kona: (808) 323-4300 • Fax (808) 323-4301 EQUAL HOUSING OPPORTUNITY Table of Contents Introductions 1 FY July 1, 2020- June 30, 2021 Annual PHA Plan 2 Appendix A: Audit of Federal Financial Assistance Programs Appendix B: Civil Rights Certification Appendix C: Certification by State or Local Official of PHA Plans Consistency with the Consolidated Plan Appendix D: Certifications of Compliance with PHA Plans and Related Regulations Appendix E: Resident Advisory Board (RAB) CommentslNarrative Appendix F: Family Self Sufficiency (FSS) Action Plan Appendix G: Waitlist Preference Appendix H: Public Hearing Narrative Introductions The Public Housing Authority (PHA) Plan process was established by the United States Housing Act of 1937 (42 U.S.C. 1437 et seq), Section 5A. Section 511 of the Quality Housing and Work Responsibility Act of 1998 (QHWRA), Pub. L. 105-276, created the requirement for submission of 5 -Year and Annual PHA Plans by all PHA's administering the Public Housing and/or Housing Choice Voucher (HCV) programs. The PHA Plan is a guide to PHA policies, programs, operations, and strategies for meeting local housing needs and goals. There are two parts to the PHA Plan: the 5 -Year Plan, which each PHA submits to the U.S. Department of Housing and Urban Development (HUD) once every 5th PHA fiscal year and the Annual Plan, which is submitted to HUD every year by non-qualified agencies. The Fiscal Year 2020 PHA Plan includes the Agency's mission and the Agency's long- range goals and objectives for achieving its mission over a five-year period. The Five - Year Plan also describes the approach to managing the Housing Choice Voucher (Section 8) programs and providing services for the upcoming year. The PHA policies, rules and requirements concerning the PHA's operations, programs and services are included in the PHA Plan. The Plan also includes statements of compliance with Civil Rights Rules and Regulations and Fair Housing Rules. The proposed 5 -year and Annual Plan will be presented to the Resident Advisory Board (RAB) on February 25, 2020 for recommendations and comments. A public hearing is scheduled on March 23, 2020, to receive oral and written testimony from the public. The finalized Annual Plan is then submitted to HUD by April 17, 2020. Streamlined Annual PHA Plan (HCV Only PHAs) U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No. 2577-0226 Expires 02/29/2016 Purpose. The 5 -Year and Annual PHA Plans provide a ready source for interested parties to locate basic PHA policies, rules, and requirements 0.,riccnunL; the PHA's operations, pmgrams, and services. and informs HUD, families served by the PHA, and members oldie public ofthe PHA's mission. L .ads and objectives for serving the needs of low- income very low- income, and extremely low- income families Applicability. Form HUD -50075 -HCV is to be completed annually by HCV -Only PHAS PHAs that meet the definition of a Standard PHA, Troubled PHA, High Performer PHA, Small PHA, or Qualified PHA do not need to submit this form, Where applicable, separate Annual PHA Plan forms are available for each of these types of PHAS Definitions. (1) High -Performer PHA A PHA that owns or manages more than 550 combined public housing units and housing choice vouchers, and was designated as a high performer on both of the most recent Public Housing Assessment System (PHAS) and Section Eight Management Assessment Pmgram (SEMAP) assessments if administenng both programs, or PHAS 'Canty administering public housing, (2) Small PHA - A PHA that is not designated as PHAS or SEMAP troubled, or at nsk of being designated as troubled, that owns c'r manages less than 250 public housing units and any number of vouchers where the total combined units exceeds 550 (3) Housing Choice Voucher (HCV' Only PHA • A PHA that administers more than 550 HCVs, was not designated as troubled in its most recent SEMAP assessment, and does not own or manage public housing. (4) Standard PHA - A PHA that owns or manages 250 or more public housing units and any number of vouchers where the total combined units exceeds 550, and that was designated as a standard performer in the most recent PHAS and SEMAP assessments (5) Troubled PHA - A PHA that achieves an overall PHAS or SEMAP score of less than 60 percent (6) Qualified PHA - A PHA with 550 or fewer public housing dwelling units and/or housing choice vouchers combined, and is not PHAS or SEMAP troubled. A. PHA Information. A.1 PHA Name HAWAII COUNTY HOUSING PHA Plan for Fiscal Year Beginning. 07/2020 PHA Inventory (Based on Annual Contributions Number of Housing Choice Vouchers (HCVs) PHA Plan Submission Type: ® Annual Submission Availability of Information. In addition to the A PHA must identify the specific location(s) and proposed PHA Plan are available for inspection reasonably obtain additional information of the submissions. At a minimum, PHAs must post encouraged to post complete PHA Plans on their 1990 Kino`ole Street, Suite 102 Hilo, Hawai*i 96720 0 PHA Consortia: (Check box if submitting AGENCY PHA Code: Contract (ACC) units at time of 2055 _111002 FY beginning, above) Submission must have the elements listed below readily available to the public Plan Elements. and all information relevant to the public hearing the PHA must provide information on [tow the public may Annual Plan, but excluded from their streamlined main office or central office of the PHA PHAs are strongly Bldg B, tad Floor ❑Revised Annual items listed in this form, PHAs where the proposed PHA Plan, PHA by the public. Additionally, PHA policies contained in the standard PHA Plans, including updates, at the official website. 75-5044 Ane Keohoknlole Hwy, Koltun Kona, Hawaii 96740 a joint Plan and complete table Wow) Participating PHAs PHA Code Program(s) in the Consortia Programs) not in the Consortia No. of Units in Each Program Lead HA: Page 1 of6 form HUD -50075 -HCV (12/2014 B. Annual Plan. B.1 Revision of PHA Plan Elements. (a) Have the following PHA Plan elements been revised by the PHA since its last Annual Plan submission' Y N ❑ ® Housing Needs and Strategy for Addressing Housing Needs. ❑ ® Deconcentration and Other Policies that Govern Eligibility, Selection. and Admissions. • ® Financial Resources • ® Rent Determination ❑ ® Operation and Management. ❑ ® Informal Review and Hearing Procedures. • ® Homeownership Programs • 0 Self Sufficiency Pmgrams and Treatment of Income Changes Resulting from Welfare Program Requirements. • ® Substantial Deviation. ® • Significant AmendmentModification. (b) If the PHA answerer{ yes for any clement, describe the revisions for each clement(s) • The OHCD's FSS action plan was completed and approved by HUD— please refer to Appendix F • The OHCD's waitlisl preferences were updated-plense refer to Appendix G B.2 New Activities (a) Does the PHA intend to undertake any new activities related to the following in the PHA's current Fiscal Year`' Y N ® • Project Based Vouchers The OHCD is currently utilizing approximately 16 percent (including proposed) of its PBV set asides. The OHCD estimates that in 2019-2020, based on availability of funding, it may Project -Base 75-120 vouchers. This follows the Annual PHA to adopt strategies and options to maintain the maximum program size of the HCV Pmgram and well as to maximize utilization of available vouchers The OHCD will work with community agencies and service providers to maximize resources and provide available services. 11.3 Most Recent Fiscal Ycar Audit. (a) Were there any findings in the most recent FY Audit? Y N N/A ❑ ® ■ (b) Ifyes, please describe: County of Hawaii Single Audit of Financial Assistance Programs Fiscal Ycar Ended June 30, 2018- See Appendix A B.4 Civil Rights Certification Forty HUD -5)077 PHef Certifications of Compliance with the P! -HA Plans and Related Regulations, must be submitted by the PHA as an electronic attachment to the PHA Plan. Please see Appendix 11 B.5 Certification by Stale or Local Officials. Fonn HUD 50077 -SL, Certification by State or Local Officials of PHI Plans Consistency with the Consolidated Platy, must be submitted by the PHA as an electronic attachment to the PHA Man. Please sec Appendix C and D 656lskaks Page 2 of 6 form HUB -50075 -HCV (12 20141 B.6 Progress Repoli. Provide a description of the PHA's progress in meeting its Mission and Goals described in its 5 -Year PHA Plan. A. Expand the supply of assisted housing 1 Apply for additional Section 8 Program vouchers should they become available. The OHCD continued 10 look for additionalfinding opportunities made available by the U.S. Departnrent of Housing and Urban Development (HUD). On December 17. 2019. the County of Hawaii received notification front HUD that it was awarded ren (10) FY19 HUD-1'AS11 vouchers The County continues to work with Veterans Affairs to develop and implement processes to lease these unit vouchers. Adopt strategies and options that maintain the maximum program size of the Housing Choice Voucher (HCV) Program The OHCD continued to maintain lease -up percentages at or above 98X of NAP budget to maintain budget levels and continued monitoring offending by utilising HUD's Tiro -Year Tool along with the PHA software system to forecast leasing and spending outcomes. The OHCD n ill also employ data collected front a 2019 rent study to monitor payment standanls in relation to the rent burden of the participants 3. Explore ways to expand service delivery to all housing markets The 011CD milked approximately 77 percent of its Project Base Voucher (PBV) set asides. The OHCD estimates that in 2019-2020, based on availability offunding, it may Project -Base additional vouchers set aside for homeless, veterans. provision ofsupportive services to persons with a disability or elderly, and a poverty rate of 20 percent or less. The OHCD collaborated with community agencies and serf ice providers to maximise resources and provide available services The O11CD will also continue to explore innovative solutions and practices to ensure an ongoing supply of affordable housing B. Improve the quality of assisted housing Strive and obtain a "High Performer', Section Eight Management Assessment Program (SEM AP) Score. The OHCD achieved a "Standard" (78Pa) rating for the certification period July 1, 2018- June 30, 2019. The OHCD implemented the use of the agency's softtrure Quality Control Review system to monitor rental transactions Staff goal setting and et ablations are ongoing. Maximize utilization of available vouchers For the funding period January 1, 2019 through December 31. 2019, the OIICD expended 99% of its available touchers providing monthly housing assistance to over 2000 program participants. 3, Explore new and existing ways to fund, coottlinate and Zink supportive services to housing The OHCD continued to collaborate with community partners to secure and link program participants to the sen ices available and projects that promote self -sur fciencv. C. Increase Housing Choices I Continue the Homeownership Option (HOP) Pmgram The OHCD continued to promote the IIOP to all eligible program applicants and participants The ONCD continued to connect program participants with rite local Self Help Programs 2. Develop strategies for providing training and outreach to landlords The OIICD continued to participate in the County's annual Fair Housing Workshops, Landlords Summits. Inter -Faith Coalition Events and other similar type of et ents to promote the benefits of participating a ith the Housing Choice I oucher program. The OHCD will explore the additional role of existing staffto serve as an owner,agent liaison to outreach and recruit. D. Promote Self -Sufficiency I, Increase the number of families enrolled in the Family Self -Sufficiency (FSS) program (as oflanuary 2.2020) Current Participant Households: 72 Total Individual Participants: 296 Households by Income Level: 30% or < 43 31%to50% 17 51%to80% 10 81%to 100% 2 1+561 skaks Page 3 of 6 form HUD -50075 -HCV (12'2014) Total Escmw Dollars Paid CY 2019 592,922.32 The OHCD continued its monthly informational meetings in East and West Hawaii. These meetings provide eligible individuals the necessary information about the benefits of the FSS and HOP Programs Enrollment actin ities included efforts to educate O11CD staff to increase pronation and referrals during appointments and at orientation presentations 2. Identify and facilitate supportive services The OHCD continued to identify and secure commitments from additional organizations and programs addressing participants' needs and barriers to self sufficiency and increased network opportunities to collaborate on new strategies and form new partnerships. E. Seek partnerships that will further the goal of affordable housing opportunities Partner with other Local, Stale, and Federal Agencies The OHCD has fostered open communication with other housing agencies it Rhin the State of Hawaii to share best practices with similar challenges. 2. Provide leadership, support and enhance partnership with Local, State, and Federal agencies to address affordable housing and supportive services issues The OHCD participated in various conntumity wide events that address the goal of ending homelessness, promoting access to programs. optimizing self-sufficiency, andf urthering fair housing. F. Ensure equal opportunity and affirmatively further fair housing I. Continue 10 impmve the distribution of Fair Housing information To commemorate Fair Housing Month in April of each year. the O11CD along with U 5 Department of Housing and Urban Development (HUD), Hawaii Civil Right Commission (HCRC). and Legal Aid Society of Hawaii (LASH) held ? free Fair Housing seminars which was open to the public. el dedicated Fair Housing website was launched on the County of Hawaii website in June of 2019 to disseminate usef d Fair Housing information attd links to the general public The Futr Housing Coordinator also was able to provide training to all Section 8 staff in September 2019 and plans to provide training on a regular basis to all the staff of the O1(CD. Me OHCD employed the various resources and training materials made available by HUD to staff and program participants to provide informational packets and access to information, G. Improve housing delivery system I. Evaluate the current administration (Odle HCV Program. The OHCD continued to look at strategies to increase operational efficiency, audit staff roles and job descriptions to ensure that work loads are balanced and completed effectively. 2. Provide on-going staff training The OHCD continued to provide individual and group training on various housing topics to housing staffinclrtding HUD's librarty of resources, the PHA's Administrative Plan, and third -party training and reference materials 3. Provide utility allowance schedule annually The calendar year 2020 utility allowance schedule was updated in October 2019. The utility schedule for single family and multifamily homes were unaffected, The OHCD will complete the ret ision process on an annual basis as required by HUD. 4. Maintain and develop effective reporting systems to impmve operation efficiency The O11CD continued to utilize MR1 Software. LLC's Housing Pro software program along with various HUD required systems to administer and manage the Housing Choice Voucher (HCI') program. 6561skaks Page 4 of 6 farm HUD -50075 -HCV (12/2014) B.7 Resident Advisory Board (RAB) Comments. (a) Did the RAB(s) provide comments to the PHA Plan? Y N RAB meeting occurred on February 25, 2020, Tuesday (a) !ryes, comments must be submitted by the PHA as an attachment to the PHA Plan PHAs must also include a narrative describing their analysis of the RAB recommendations and the decisions made on these recommendations Please see Appendix E for RAB comments/narrative Instructions for Preparation of Form HUD -50075 -HCV Annual PHA Plan for HCV Only PHAs A. PHA Information, All PHAs mut complete Ihrs rse_tion. (24 CFR ''+03?3(414e1) A.I Include the full PHA Name. PHA Code. PHA Type, PHA Fiscal Year Beginning (MM, TINY), Number of Housing Choice Vouchers (HCVs), PHA Plan Submission Type. and the Availability of Information, specific location(s) of all information relevant to the public hearing and proposed PHA Plan PHA Consortia: Cheek box if submitting a Joint PHA Plan and complete the table (24 CFR :943 1281a)) B. Annual Plan. All PHAs must complete this section. t24 CFR §903.1 I1c}(3)) B.1 Revision of PHA Plan Elements. PHAs must: Identify specifically which plan elements listed below that have been revised by the PHA. To specify which elements have been revised, mark the "yes— box. If an element has not been revised, mark'"no." ❑ Housing Needs and Strategy for Addressing Housing Needs. Provide a statement addressing the housing needs of low-income, very low-income families who reside in the PHA's jurisdiction and other families who are on the Section 8 tenant -based waiting list. The statement must identify the housing needs of (i) families with incomes below 30 percent of area median income (extremely low-income), (ii) elderly families and families with disabilities, and (iii) households of various races and ethnic groups residing in the jurisdiction or on the waiting list based on information provided by the applicable Consolidated Plan, information provided by HUD, and other generally available data_ The identification ofhousing needs must address issues of affontabiliiy, supply, quality, accessibility, size of units, and location. (?4 CFR &903.7(a)U2 and 24 CFR ¢903.7(a)(2)(i)}. Provide a description of the PHA's strategy for addressing the housing needs of families in the jurisdiction and on the waiting list in the upcoming year, 24 CFR:903.7(aN2)(ii,) ❑ Deconcentration and Other Policies that Govern Eligibility, Selection, and Admissions. A statement ofthe PHA's policies that govern resident or tenant eligibility, selection and admission including admission preferences for HCV. (24 CFR ;903.7(b)) ❑ Financial Resources. A statement of financial resources, including a listing by general categories, of the PHA's anticipated resources, such as PHA HCV funding and other anticipated Federal resources available to the PHA, as well as tenant rents and other income available to support tenant -based assistance. The statement also should include the non -Federal sources of funds supporting each Federal program, and state the planned use for the resources (24 CFR :9O3.7(c)) ❑ Rent Determination. A statement of the policies of the PHA governing rental contributions of families receiving tenant•based assistance, discretionary minimum tenant rents , and payment standard policies. (24 CFR ;903.71d)) ❑ Operation and Management. A statement that includes a description of PHA management organization, and a listing of the programs administered by the PHA. (24 CFR :903.7(113 54)). ❑ Informal Review and Hearing Procedures. A description of the informal hearing and review pmcedures that the PHA makes available to its applicants. (24 CFR :903.7{t)) ❑ Homeownership Programs. A statement describing any homeownership programs (including project number and unit count) administered by the agency under section 8y of the 1937 Act, or for which the PHA has applied or will apply for approval. (24 CFR §903.7(k)) ❑ Self Sufficiency Programs and Treatment of Income Changes Resulting from 1Velfnre Program Requirements. A description of any PHA programs relating ti.3 services and amenities coordinated, promoted, or provided by the PHA for assisted families, including those resulting from the PHA's partnership with other entities, for the enhancement of the economic and social self-sufficiency of assisted families, including programs provided or offered as a result of the PHA's partnerships with other entities, and activities under section 3 of the Housing and Community Development Act of 1968 and under requirements for the Family Self -Sufficiency Program and others. Include the program's size (including required and actual size of the FSS program) and means of allocating assistance to households. (24 CFR :903.711)(i)) Describe how the PHA will comply with the requirements of section I2(c) and (d i of the 1937 Act that relate to treatment of income changes resulting from welfare pmgram requirements. (24 CFR ;903.7(I)(iii)). 6561skaks Page 5 of 6 form HUD -50075 -HCV (12/2014) ❑ Substantial Deviation. PHA must provide its criteria for determining a "substantial deviation" to its 5.Ycar Pian. (24 CFR 4903.7(0(2 Xi)) ❑ Significant Amendment/Modification PHA must provide its criteria for determining a "Significant Amendment or Modification" to its 5 -Year and Annual Plan Should the PHA fail to define 'significant amendment/modification', HUD will consider the following to be 'significant amendments or modifications': a) changes to rent or admissions policies or organization of the waiting list; or b) any change with regani to homeownership programs. See guidance on HUD's website at Notice PIH 1999-51. (24 CFR *903.7(r)(21(iiD !Fatty boxes are marked "yes", describe the revision(s) to those element(s) in the space provided B.2 New Activity. If the PHA intends to undertake new activity using Housing Choice Vouchers (HCVs) for new Project -Based Vouchers (PBVs) in the current Fiscal Year, mark "yes" for this element, and describe the activities to be undertaken in the space provided. lithe PHA does not plan to undertake this activity, mark "no" (24 CFR ; 983.57(b)( 11 and Section 8(I 3)(C) of the United States Housing Act of 1937. ❑ Project -Based Vouchers (PBV). Describe any plans to use HCVs for new project -based vouchers If using PBVs, provide the projected number of project -based units and general locations, and describe how project -basing would be consistent with the PHA Plan. B3 Most Recent Fiscal Year Audit. lithe results of the most recent fiscal year audit for the PHA included any findings, mark "yes" and descnbe those findings in the space provided. (24 CFR ;s>i13.1 I(c)(3), 24 CFR ;903.7(x)) 8.4 Civil Rights Certification. Form HUD -50077, PHA Certifications of Compliance +tali the PHe1 Plans and Related Regulation, must be submitted by the PHA as an electronic attachment to the PHA Plan. This includes all certifications relating to Civil Rights and related regulations. A PHA will be considered in compliance with the AFFH Certification if: it can document that it examines its programs and proposed programs to identify any impediments to fair housing choice within those programs; addresses those impediments in a reasonable fashion in view oldie resources available; works with the local jurisdiction to implement any of the jurisdiction's initiatives to affirmatively further fair housing; and assures that the annual plan is consistent with any applicable Consolidated Plan for its jurisdiction. (24 CFR ;903.7(o)) B.5 Certification by State or Local Officials. Form HUD -50077 -SL, Certification by State or Local Officials r fPHA Plans Consistence u ith the Consolidated Plan, including the manner in which the applicable plan contents are consistent with the Consolidated Plans, must be submitted by the PHA as an electronic attachment to the PHA Plan, (24 CFR ;903.15) B.6 Progress Report. For all Annual Plans following submission of the first Annual Plan, a PHA must include a brief statement of the PHA's progress in meeting the mission and goals described in the 5 -Year PHA Plan. (24 CFR ;903.1 1(c)(3), 24 CFR ;903.71 rl(11) 11.7 Resident Advisory Board (RAB) comments lithe RAB provided comments to the annual plan, mark "yes," submit the comments as an attachment to the Plan and describe the analysis of the comments and the PHA's decision made on these recommendations. (24 CFR ;903.13(c), 24 CFR ;903.19) This information collection is authorized by Section 511 of the Quality Housing and Work Responsibility Act, which added a new section 5A to the U.S. Housing Act of 1937, as amended, which Introduced the Annual PHA Plan. The Annual PHA Plan provides a ready source for interested parties to locate basic PHA policies, rules, and requirements concerning the PHA's operations, programs, and services, and informs HUD, families served by the PHA, and members of the public for serving the needs of low Income, very low. Income. and extremely low. income families. Public reporting burden for this information collection is estimated to average 4.5 hour per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. HUD may not collect this information, and respondents are not required to complete this form, unless it displays a currently valid OMB Control Number. Privacy Act Notice. The United States Department of Housing and Urban Development is authorized to solicit the Information requested In this form by virtue of Title 12, U S. Code, Section 1701 et seq., and regulations promulgated thereunder at Title 12, Code of Federal Regulations. Responses to the collection of information are required to obtain a benefit or to retain a benefit, The information requested does not lend itself to confidentiality 656;skak: Page 6 of 6 form HUD -50075 -HCV (1212014) Appendix A: County of Hawaii - Single Audit of Federal Financial Assistance Programs COUNTY OF HAWAII STATE OF HAWAII SINGLE AUDIT OF FEDERAL FINANCIAL ASSISTANCE PROGRAMS Fiscal Year Ended June 30, 2018 N&KCPAs, Inc. AMERICAN SAVINGS BANK TOWER 1 1001 8 SHOP STREET, SUITE 1700 HONOLULU, HAWAII 96813 3696 T (808) 5242255 F (808) 523-2090 1 nkcpa cam N&K CPAs, Inc. ACCOUNTANTS 1 CONSU TANTS March 28, 2019 To the Chair and Members of the County Council County of Hawai'i AMER CAN SAV;NGS BANK TOWER 1001 BISHOP STREET, SUITE 1700 HONOLULU, HAWAII 968133696 T (808) 524 2255 F (808) 523 2090 We have completed our financial audit of the basic financial statements and other supplementary information of the County of Hawai'i, State of Hawaii (the County), as of and for the fiscal year ended June 30, 2018. Our report containing our opinions on those basic financial statements is included in the County's Comprehensive Annual Financial Report. We submit herein our reports on the County's internal control over financial reporting and compliance, the County's compliance with requirements that could have a direct and material effect on each of its major federal programs and internal control over compliance, and our report on the schedule of expenditures of federal awards. OBJECTIVES OF THE AUDITS The primary purpose of our audits was to form opinions on the faimess of the presentation of the County's basic financial statements as of and for the fiscal year ended June 30, 2018, and to comply with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), which establishes audit requirements for state and local governments that receive federal financial assistance. More specifically, the objectives of the audits were as follows: 1. To provide a basis for an opinion on the fairness of the presentation of the County's basic financial statements. 2. To report on internal control over financial reporting and compliance with provisions of laws, regulations, contracts, and grant agreements, noncompliance with which could have a direct and material effect on the determination of financial statement amounts in accordance with Government Auditing Standards. 3. To report on internal control over compliance related to each major federal program and an opinion on compliance with federal statutes, regulations, and the terms and conditions of federal awards that could have a direct and material effect on each major federal program in accordance with the Single Audit Act Amendments of 1996 and the Uniform Guidance. 2 N&K CPAs, Inc, ACCOUNTANTS I CONSULTANTS SCOPE OF THE AUDIT Our audit was performed in accordance with auditing standards generally accepted in the United States of America as prescribed by the American Institute of Certified Public Accountants; Government Auditing Standards, issued by the Comptroller General of the United States; and the audit requirements of the Uniform Guidance. The scope of our audits included an examination of the transactions and accounting records of the County for the fiscal year ended June 30, 2018. ORGANIZATION OF THE REPORT This report is presented in four parts as follows: Part I Our report on internal control over financial reporting and on compliance and other matters. Part II Our report on compliance for each major federal program; report on internal control over compliance; and report on the schedule of expenditures of federal awards required by the Uniform Guidance. Part III - The schedule of findings and questioned costs. Part IV The summary schedule of prior audit findings. We wish to express our sincere appreciation for the excellent cooperation and assistance extended by the staff of the County. Sincerely, %V,- K ems-, .rNr. N&K CPAs, INC. 3 COUNTY OF HAWAII, STATE OF HAWAII TABLE OF CONTENTS PART 1 REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING AND ON COMPLIANCE AND OTHER MATTERS Report on Intemal Control over Financial Reporting and on Compliance and Other Matters Based on an Audit of Financial Statements Performed in Accordance with Government Auditing Standards PART II REPORT ON COMPLIANCE FOR EACH MAJOR FEDERAL PROGRAM; REPORT ON INTERNAL CONTROL OVER COMPLIANCE; AND REPORT ON THE SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS REQUIRED BY THE UNIFORM GUIDANCE Report on Compliance for Each Major Federal Program; Report on Internal Control over Compliance; and Report on the Schedule of Expenditures of Federal Awards Required by the Uniform Guidance Schedule of Expenditures of Federal Awards Notes to Schedule of Expenditures of Federal Awards PART III SCHEDULE OF FINDINGS AND QUESTIONED COSTS Page 6-7 9-11 12.22 23 Schedule of Findings and Questioned Costs 25 PART IV SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS Status Report 27 4 PART I REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING AND ON COMPLIANCE AND OTHER MATTERS 5 I N&K CPAs, Inc. ACCOUNTANTS 1 CONSULTANTS AMER CAN SAVINGS BANK TOWER 1001 BISHOP STREET, SUITE 1700 HONOLULU, HAWAl 96813 3696 T (808) 5242255 F (808) 5232090 REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING AND ON COMPLIANCE AND OTHER MATTERS BASED ON AN AUDIT OF FINANCIAL STATEMENTS PERFORMED IN ACCORDANCE WITH GOVERNMENT AUDITING STANDARDS INDEPENDENT AUDITOR'S REPORT To the Chair and Members of the County Council County of Hawaii We have audited, in accordance with the auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards issued by the Comptroller General of the United States, the financial statements of the governmental activities, the business -type activities, the discretely presented component unit, each major fund, and the aggregate remaining fund information of the County of Hawaii, State of Hawaii (the County), as of and for the fiscal year ended June 30, 2018, and the related notes to the financial statements, which collectively comprise the County's basic financial statements, and have issued our report thereon dated December 28, 2018. Internal Control Over Financial Reporting In planning and performing our audit of the financial statements, we considered the County's internal control over financial reporting (internal control) to determine the audit procedures that are appropriate in the circumstances for the purpose of expressing our opinions on the financial statements, but not for the purpose of expressing an opinion on the effectiveness of the County's internal control. Accordingly, we do not express an opinion on the effectiveness of the County's internal control. A deficiency in internal control exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, misstatements on a timely basis. A material weakness is a deficiency, or a combination of deficiencies, in internal control, such that there is a reasonable possibility that a material misstatement of the entity's financial statements will not be prevented, or detected and corrected on a timely basis. A significant deficiency is a deficiency, or a combination of deficiencies, in internal control that is Tess severe than a material weakness, yet important enough to merit attention by those charged with governance. 6 N&K CPAs, Inc. ACCOUNTANTS J CONSULTANTS Our consideration of internal control was for the limited purpose described in the first paragraph of this section and was not designed to identify all deficiencies in internal control that might be material weaknesses or significant deficiencies. Given these limitations, during our audit we did not identify any deficiencies in internal control that we consider to be material weaknesses. However, material weaknesses may exist that have not been identified. Compliance and Other Matters As part of obtaining reasonable assurance about whether the County's financial statements are free from material misstatement, we performed tests of its compliance with certain provisions of laws, regulations, contracts, and grant agreements, noncompliance with which could have a direct and material effect on the determination of financial statement amounts. However, providing an opinion on compliance with those provisions was not an objective of our audit, and accordingly, we do not express such an opinion. The results of our tests disclosed no instances of noncompliance or other matters that are required to be reported under Government Auditing Standards. Purpose of this Report The purpose of this report is solely to describe the scope of our testing of internal control and compliance and the results of that testing, and not to provide an opinion on the effectiveness of the entity's internal control or on compliance. This report is an integral part of an audit performed in accordance with Government Auditing Standards in considering the entity's internal control and compliance. Accordingly, this communication is not suitable for any other purpose. Ni. K VA-, 2ivc, Honolulu, Hawai'i December 28, 2018 7 PART II REPORT ON COMPLIANCE FOR EACH MAJOR FEDERAL PROGRAM; REPORT ON INTERNAL CONTROL OVER COMPLIANCE; AND REPORT ON THE SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS REQUIRED BY THE UNIFORM GUIDANCE 8 gN&K CPAs, Inc. ACCOUNTANTS I CONSULTANTS AMERICAN SAVINGS BANK TOWER 1001 BISHOP STREET, SUITE 1700 HONOLULU, HAWAII 96813 3696 T (808) 524-2255 F (808) 523 2090 REPORT ON COMPLIANCE FOR EACH MAJOR FEDERAL PROGRAM; REPORT ON INTERNAL CONTROL OVER COMPLIANCE; AND REPORT ON THE SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS REQUIRED BY THE UNIFORM GUIDANCE INDEPENDENT AUDITOR'S REPORT To the Chair and Members of the County Council County of Hawai'i Report on Compliance for Each Major Federal Program We have audited the County of Hawai'i, State of Hawai'i's (the County) compliance with the types of compliance requirements described in the OMB Compliance Supplement that could have a direct and material effect on each of the County's major federal programs for the fiscal year ended June 30, 2018. The County's major federal programs are identified in the summary of auditor's results section of the accompanying schedule of findings and questioned costs. Management's Responsibility Management is responsible for compliance with federal statutes, regulations, and the terms and conditions of its federal awards applicable to its federal programs. Auditor's Responsibility Our responsibility is to express an opinion on compliance for each of the County's major federal programs based on our audit of the types of compliance requirements referred to above. We conducted our audit of compliance in accordance with auditing standards generally accepted in the United States of America; the standards applicable to financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United States; and the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Those standards and the Uniform Guidance require that we plan and perform the audit to obtain reasonable assurance about whether noncompliance with the types of compliance requirements referred to above that could have a direct and material effect on a major federal program occurred. An audit includes examining, on a test basis, evidence about the County's compliance with those requirements and performing such other procedures as we considered necessary in the circumstances. 9 N&K CPAs, lnc, ACCOUNTANTS l CONSULTANTS We believe that our audit provides a reasonable basis for our opinion on compliance for each major federal program. However, our audit does not provide a legal determination of the County's compliance. Opinion on Each Major Federal Program In our opinion, the County complied, in all material respects, with the types of compliance requirements referred to above that could have a direct and material effect on each of its major federal programs for the fiscal year ended June 30, 2018. Report on Internal Control Over Compliance Management of the County is responsible for establishing and maintaining effective internal control over compliance with the types of compliance requirements referred to above. In planning and performing our audit of compliance, we considered the County's internal control over compliance with the types of requirements that could have a direct and material effect on each major federal program to determine the auditing procedures that are appropriate in the circumstances for the purpose of expressing an opinion on compliance for each major federal program and to test and report on internal control over compliance in accordance with the Uniform Guidance, but not for the purpose of expressing an opinion on the effectiveness of internal control over compliance. Accordingly, we do not express an opinion on the effectiveness of the County's internal control over compliance. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. A material weakness in internal control over compliance is a deficiency, or combination of deficiencies, in internal control over compliance, such that there is a reasonable possibility that material noncompliance with a type of compliance requirement of a federal program will not be prevented, or detected and corrected, on a timely basis. A significant deficiency in internal control over compliance is a deficiency, or a combination of deficiencies, in internal control over compliance with a type of compliance requirement of a federal program that is less severe than a material weakness in internal control over compliance, yet important enough to merit attention by those charged with governance. Our consideration of internal control over compliance was for the limited purpose described in the first paragraph of this section and was not designed to identify all deficiencies in internal control over compliance that might be material weaknesses or significant deficiencies. We did not identify any deficiencies in internal control over compliance that we consider to be material weaknesses. However, material weaknesses may exist that have not been identified. 1g N&K CPAs, Inc. ACCOUNTANTS CONSU_TANTS The purpose of this report on internal control over compliance is solely to describe the scope of our testing of internal control over compliance and the results of that testing based on the requirements of the Uniform Guidance. Accordingly, this report is not suitable for any other purpose. Report on Schedule of Expenditures of Federal Awards Required by the Uniform Guidance We have audited the financial statements of the governmental activities, the business - type activities, the discretely presented component unit, each major fund, and the aggregate remaining fund information of the County as of and for the fiscal year ended June 30, 2018, and the related notes to the financial statements, which collectively comprise the County's basic financial statements. We issued our report thereon dated December 28, 2018, which contained unmodified opinions on those financial statements. Our audit was conducted for the purpose of forming opinions on the financial statements that collectively comprise the County's basic financial statements. The accompanying schedule of expenditures of federal awards is presented for purposes of additional analysis as required by the Uniform Guidance and is not a required part of the basic financial statements. Such information is the responsibility of management and was derived from and relates directly to the underlying accounting and other records used to prepare the basic financial statements. The information has been subjected to the auditing procedures applied in the audit of the basic financial statements and certain additional procedures, including comparing and reconciling such information directly to the underlying accounting and other records used to prepare the basic financial statements or to the basic financial statements themselves, and other additional procedures in accordance with auditing standards generally accepted in the United States of America. In our opinion, the schedule of expenditures of federal awards is fairly stated in all material respects in relation to the basic financial statements as a whole. A(/- 4 e,,Qr, manic. Honolulu, Hawai'i March 28, 2019 11 County of Hawal'i, State of Hawaii SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Fiscal Year Ended June 30, 2018 Federal GrantorJPassdhrough GrantorlProgram ar Cluster Title DEPARTMENT OF AGRICULTURE Food and Nutrition Service Passed Through the State Department of Education Federal Pass -Through Federal Total Provided CFDA Entity Identifying Program Federal Through to Number Grant Number Number Award Amount Expenditures Subrecipknta Summer Food Service Program far Children ' J 55= hA 1707.8 S 42,375 $ 42.375 $ Total Department of Agriculture 42.375 DEPARTMENT OF COMMERCE National Dceank and Atmospheric Administration Passed Through the Stale Department of Business, Economic Development and Tounsm. Coastal Zone Management Adrneristra88on Awards 11 419 NA16N0S4190093 N/A 374 716 17 497 Hawai Coastal Zone Management Program NA17N0S4190102 N/A 398,401 248362 Subtotal CFDA 11 419 265.859 Total Department of Commerce 265,859 — DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Office of Housing Section 8 - Housing Assistance Payments Program '4 95 Kutaimano Elderly Housing HI 10 0002001 NIA 360,836 $ 224.921 $ The accompanying notes are an integral part of this schedule. County of Hawaii, State of Hawaii SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (Continued} Fiscal Year Ended June 30, 2018 Federal Grantor/Pass-Through Grantor/Program or Cluster TitIe DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT (Continued) Community Planning and Development Community Development Block Grants/State s Program Federal Pass -Through Federal Total Provided CFDA Entity Identifying Program Federal Through to Number Grant Number Number Award Amount Expenditures Subrecipients and Non -Entitlement Grants in Huai 14.228 8.14-0H•15A002 NIA 5 2,677.897 $ 378,796 $ 242 708 6.15 -DH -150002 NIA 2,465,271 622327 B -16 -DH -154002 NIA 2491,306 1,027,882 981,823 Program Income WA 6,575 6,575 B•17 -DH -15-0002 NIA 2,524,362 1,011,378 957,560 Program Income NIA 205,722 42,644 Subtotal CFDA 14.228 3252,680 2,461,890 Passed Through the Hawaii Housing France and Development Corporation: Home Investment Partnerships Program 14233 M•14•SG•15-0100 Fd416-02 452.684 M -15 -SG -15-0100 FIN 1644 2.652059 631,536 Program Income 46,146 Subtotal CFDA 14.239 721,160 253.230 Public and Indian Housing Section 8 Housing Choice Vouchers t4 871 H1002AF 2017 NIA 1,949,059 1777,650 — H1002V0 2017 NIA 17,658,595 4193,051 — HI002AF2018 NIA 1,794095 237,807 111002V0 2018 WA 16,556,706 7,555,227 Program Income 1,470.448 Sublolal CFDA 14.871 $ 20.234.183 ' 5 u The accompanying notes are an integral part of this schedule. County of Hawaii, State of Hawai'i SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (Continued) Fiscal Year Ended June 30, 2018 Federal Graotor1Pass•Through Grantor,Program or Cluster Tide Federal Pass•Through Federal Total Provided CFDA Entity Identifying Program Federal Through to Number Grant Number Number Awud Amount Expenditures Subrecipients DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT (Continued) Family SellSulfaency Program 14.B' E 't002F$H1BOAO14 2017 NIA 5 66,204 5 29,826 5 «10O2FSH1BOA014 2018 NIA 66,937 18.360 — Subtotal CFDA 14.896 48.186 ® ' Total Department of Housing and Urban Development 24,481.130 2.715,120 DEPARTMENT OF THE INTERIOR Office of the Secretary Payments in Lieu of Taxes 15 22F. N/A N/A 334,504 334,504 Fish and Wildlife Service National Wildlife Refuge Fund 15.659 N;A WA 68,393 68.393 Total Department of the Interior 402.897 — DEPARTMENT OF JUSTICE Office of Juvenile Justice and Delinquency Prevention Passed through the Stale Department of Human Services: Juvenile Justice and Delinquency Prov ntion - Allocation to States 16.540 2016 -JF -FX -0022 DHS -17-0Y5.702 400,000 202.556 202.556 Bureau of Justice Statistics Passed through the State Depanmentolthe Attorney General: 16.554 2015 -RU -BX -K010 N/A 15.000 4 231 National Criminal History Improvement Program 2013-MU-BX4K056 2013-MU.BX•K056 36,000 36.000 — Subtotal CFDA 16.5545 5 40.231 g — The accompanying notes are an integral part of this schedule County of Hawai'1, State of Hawaii SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (Continued) Fiscal Year Ended June 30, 2018 Federal GrantorWPass-Through Grantor(Program or Cluster Tide Federal Pass -Through Federal Total Provided CFDA Entity Identifying Program Federal Through to Number Grant Number Number Award Amount Expenditures Subredptents DEPARTMENT OF JUSTICE (Continued) Office for Victims of Crime Passed through the State Departrnena of the Attorney General. Crime Victim Assistance 16.575 2014-VA-GX-0035 14 -VA -04 S 355,093 S 37,680 9 24,324 2015 -VA -G%43035 15VA-04 1,649,397 810,451 2016-VA-GX-0063 16 -VA -07 101,745 26568 Subtotal CFDA 16.575 874,699 190,626 Violence Against Women Office Passed through the Stale Depadmenf olAttomey General Violence Against Women Formula Grants tEsag STOP Violence Against Women 2015•WF-AX-0024 i5 -WF -03 54 137 54,137 SAFE On Call Pay & SANE Coad nato( 2014 -WF -AX -0019 14 -WF -07 53,586 49 698 Sexual Assault Kit SAK) Testing 2015.WF-AX40024 15 -WF -07 53,205 B.I13 Subtotal CFDA 16.588 111,948 Office of Community oriented Policing Services Public Safety Partnership and Community Poking Grants COPS 16 7 t 2014ULWX0037 N;A 250,000 $ 89,478 5 The accompanying notes are an integral part of this schedule. County of Hawaii, State of Newell SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (Continued) Fiscal Year Ended June 30, 2018 Federal Pass -Through Federal Total Provided CFDA Entity Identifying Program Federal Through to Federal GrantorPPass•Through GrantorlProgram or Cluster Title Number Grant Number Number Award Amount Expenditures Subrecipients DEPARTMENT OF JUSTICE (Continued) Bureau of Justice Assistance Edward Byrne Memorial Justice Assistance Grant Programs. 16 738 Passed through the Stale Department ofAltomey General. Statewide Muttl-Junsdktional Drug Task Force (SMDTF 2416 -DJ -8X-01189 16 -DJ -DI 5 45,334 5 6,500 5 JAG Specialized Sex Assault Unit 2014 -DJ -BX -4910 14 -DJ -01 272 923 56,618 2015•DJ-BX-0342 15.0J-08 55 695 55,695 Hawaii Narcotics Task Force 2015•DJ•BX•0342 IS -DJ -03 44 162 36517 Subtotal CFDA 16.738 955.434 National Institute of Justice Passed through the State Department of Attorney General Paul Coverde9 Forensic Sciences Improvement Grant Program 6.742 Y' 17 -: D•BX NI 17 _C •::1 50464 19,282 Criminal Division Equitable Sharing Program 16 922 Asset Forfeitures H1D:11013A NIA 374 374 HI0010000 NIA 521 521 Subtotal CFDA 16.922 895 Total Department of Justice $ 1,494,519 1 393 182 The accompanying notes are an integral part of this schedule. County of Hawaii, State of Hawaii SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (Continued) Fiscal Year Ended June 30* 2018 Federal GrantodPass•Through Grantor1Program or Cluster Ede DEPARTMENT OF LABOR Employment and Training Administration Passed through the State Department of Labor and Indusl+ar Relations Senior Community Semce Employment Program Subtotal CFDA 17 235 W1OA Cluster WIOA Adult Program Subtotal CFDA 17.258 WIOA Youth Activities Subtotal CFDA 17.259 WIOA Dislocated Worker Formula Grants Subtotal CFDA 17.278 Total MCA Cluster Total Department of Labor Federal CFDA Number Grant Number Pass -Through Entity Identifying Number Federal Total Provided Program Federal Through to Award Amount Expenditures Subrec pients 17.235 AD -30402.17.55-A-15 AD -30402.17.55-A-16 17.258 AA•26775-15.55-A-15 AA -26775.16.55•A-15 AA -26775.17.55-A-15 17.259 AA -26775.16.55•A-15 AA -26775.17.55•A•15 17.278 AA -26775.15.55•A-15 M -26775.16.55-A-15 AA -26775-' 7. 55-A•15 PYI6-SCSEP•1-1-HCOA 5 327 726 S 24.877 PY16•SCSEP-H-HCOA 359,686 301,923 326,800 WIOA•15•A&DWP-H WIOA•16-A&1W141 WI0A•17-A&DWP-H WIOA-I6-YP-H WI0A-I7-YP-H WI0A-15-A&DWP4H WIDA-16-A&DWP-H WIOA•17•A&DWP-H The accompanying notes are an integral part of this schedule 387,934 422,171 480146 7.498 3,886 365,215 291.775 289,333 178,242 417,471 282,880 192,831 461122 366 943 353,926 19 002 416,431 0 276,518 6,004 2,653 218,352 177,324 1,044,689 • 836842 $ 1,371 489 $ 836.042 County of Hawat'i, State of Hawaii SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (Continued) Fiscal Year Ended June 30, 2018 Federal Grantor!Pass•Through GrantorlProgram or Cluster Tttle Federal Pass•Through Federal Total Provided CFDA Entity Identifying Program Federal Through to Number Grant Number Number Award Amount Expenditures Subrecipients DEPARTMENT OF TRANSPORTATION Federal Highway Adminlsiration PassedLhreugh the State Department of Transportation: Highway Planning and Construction: 20.205 Bridge tnspectiontAppraisals BR-NBIS(55) 13033 S 160,000 $ 25,345 S Bridge InspectionlAppraisals BR•NBIS(67) 16002 160.800 101 619 Ma:ralahaa Hwy Widening, Marta Road NH•019-1(044) 12332 20.285,600 644,772 Alii Drive ROW RS -0187(1) 00014 3127.200 85 RS -0187(4) 10010 6,564,594 85 Hakalau Bridge North Abutment 5TP•0100(073) 17025 1.588,104 423464 4741 Alii Drive Culvert Replacement STP -0186(1) 97029 462 885 13,228 Kaiminani Drive Roadway Imp, Mamalahoa Hwy toAhiahi St STP -0198(1) 11007 9,434,330 1498 Kaiminani Drive Roadway Imp, Ahiahi S1 to Me Keohokalole Hwy STP -0198(2) 13034 16,126,147 3,646 Kamehameha Avenue Resurfacing, Wailoa Bridge to Ponohawai St STP•1910(1) 05003 12,842 182 1,481 Puainako Street Extension, Komohana 51 to Country Club Rd STP -2000(4) 00030 26.886 000 564 Waianuenue Ave Imp, Rainbow Dr to Akolea Rd STP•2720(0011 13019 1.3.Y. CO3 •7140 Kawaiani Street Improvements Iwalari to Poha wla' Street STP -2760(2) 99021 21.469.625 6,352.354 Manono St Improv Lanikaula to Kekuanaoa STP•2770(004) 11043 5,589 416 111071 Subtotal CFDA 20.205 7,672,272 Federal Transit Administration Passed through the State Department of Transportation. Federal Transit Capital Investment Grants 20 500 H -2016-004 NIA 1,119,817 5 392.638 g The accompanying notes are an integral part of this schedule. County of Hawaii, State of Hawaii SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (Continued) Fiscal Year Ended June 30, 2018 Federal Granto 1Pass•Through Grantor/Program or Cluster rm. Federal CFDA Number Grant Number DEPARTIdENT OF TRANSPORTATION (Continued) National Highway Traffic Safety Administration Passed through the State Department of Transportation: Highway Safety Cluster State and Community Highway Safety Speed Enforcement Traffic Investigation Program Distracted Driving Subtotal CFDA 20 600 National Priority Safety Programs Data Grant Seatbelt Enforcement Roadblock Program Subtotal CFDA 20616 Total Highway Safety Cluster 20.600 20.616 18X9204020 18X9204020 18X9204020 69A37518300004020 16X9204020 18X9204020 18X9204050H117 18X920405C 18X920405C 1842040513 69A37518300004058 18X9204050 18X9204050 Pass -Through Federal Total Provided Entity identifying Program Federal Through to Number Award Amount Expenditures Subradpients SC17-06(0141-02) SC1806(01-H-02) PT17-01(0241.01) PT18-0t(02-H-01) D0t740(02-H-01) 0016-t0(0241-01) AL18-02(03.5.01) TR17-03(04•H-01) TR18-03(04-4-01) DP17-05(014021 0P1805(01 -H-02) ALIT -02{0141-02) AM -02(0141.02) The accompanying notes are an integral part of this schedule. $ 103,068 $ 49586 6 171,036 111,296 53,250 10,004 80,750 24,700 57,430 15,435 57,430 31,655 242,676 135,596 5,762 135,680 122,883 14,610 1,697 78,843 20,179 78,869 30,446 52,655 10,076 65,220 21,323 212.366 5 455,042 5 County of Hawaii, State of Hawaii SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (Continued) Fiscal Year Ended June 30, 2018 Federal Pass -Through Federal Total Provided CFDA Entity Identifying Program Federal Through to Federal GrantarfPass•Through GrantorfProgram or Cluster Title Number Grant Number Number Award Amount Expenditures Subrecipients DEPARTMENT OF TRANSPORTATION (Continued) Alcohol Open Container Requirements 20 607 Roadblock Program 18X9205464 ALI7.02[01402j $ 153,305 $ 41,193 5 - Minimum Penalties for Repeat Offenders for Dining While Intoxicated 20.608 Prosecutor's Training 89A37518300004020 AL 18-02(01-H•02) 124,296 72.281 — TotalDepartmentofTransportation 5,633.426 — DEPARTMENT OF HEALTH AND HUMAN SERVICES Administration for Community Living Passed through the State Executive Office on Aging. Special Programs for the Aging • Title II Part 0 • Disease Cr Prevention and Health Promotion Services 93 043 30-0.2016 HA2016NO3 15,735 3,019 Ammo Cluster Special Programs for the Aging -Tide ,, Pan B -Grants for Supportive Services and Senior Centers 93.044 313.4-2C 16 NA2016NO3 492,169 55,281 313-0-2017 HA2016NO3 457,773 398,672 Subtotal CFDA 93.044 453.953 Special Programs for the Agng • Title Part C - Nutrition Services 93.045 3C1-4•2017 HA2016NO3 280,706 104,083 3C1-4•2018 HA2016NO3 364,862 193130 3C2-0.2016 HA2016NO3 204,394 18,484 — 3C2.4.2017 HA2016NO3 122,733 64,497 3C2-4-2018 HA2016NO3 220,911 101.273 Subtotal CFDA 93.045 5 481,467 5 — The accompanying notes are an integral part of this schedule. County of Hawaii, State of Hawaii SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (Continued) Fiscal Year Ended June 30, 2018 Federal Pass -Through Federal Total Provided CFDA Entity Identifying Program Federal Through to Federal Grantor:Pass•Through Grantor(Program or Cluster Tide Number Grant Number Number Award Amount Expenditures Subreciplents DEPARTMENT OF HEALTH AND HUMAN SERVICES (Continued) Nulntion Services Incentive Program 93-053 WA NS P17 5 89,114 5 89.1 t4 5 Total Agng C uster 1,024534 National Family Caregiver Support. T. I : Pa,: E 93,052 3E-4-2015 HA2015NO3 115,636 35,545 3E-4-2016 HA2016NO3 133,637 133,637 3E.4-2017 HA2016NO3 133,468 9.733 Subtotal CFDA 93.052 178 921 Substance Abuse and Mental Health Services Administration Paned through the State Department olHealth: Substance Abuse and Mental Health Senrtces Projects of Regional and National Significance 53243 SP020167 ASO LOG NO. 16-162 110,000 25,409 SP020167 ASO LOG NO 16.162 125,000 72.325 Subtotal CFDA 93.243 97,734 Centers for Disease Control and Prevention Passed UK* the Stale D6parfrnent of Health. Stale and Local Pubic Health Actions to Prevent 0besity Diabetes, Heart 93 757 6NU58DP005502.02-02 N/A 24,500 20,401 Disease and Stroke (PPHF, NU58DP005502.04.00 NIA 9,700 6,156 26,557 Subtotal CFDA 93 757 Total Department of Health and Human Services 8 1.330.765 5 The accompanying notes are an integral part of this schedule County of Hawaii, State of Hawaii SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (Continued) Fiscal Year Ended June 30, 2018 Federal GrantorWPass-Through GrantoriProgram or Cluster Tide Federal CFDA Number Grant Number Pass•Thmugh Entity Identifying Number CORPORATION FOR NATIONAL AND COMMUNITY SERVICE Retired and Senior ;,:k.nteer Program Total Corporation for National and Community Service DEPARTMENT OF HOMELAND SECURITY Federal Emergency Management Agency (FEMA) Passedllvough the State Departmenl.-f Oefeese: Disaster Grants - PubBc Assistant a (Presidentially Declared Disasters) Kihalo Earthquake Assistance to Firefighters Grant Homeland Secunty Grant Program Total Department of Homeland Security OFFICE OF NATIONAL DRUG CONTROL POIJCY Hawaii Impact Subtotal CFDA 7 ; Total Office of National Drug Control Policy TOTAL EXPENDITURES OF FEDERAL AWARDS 941X2 IBSRPHI002 97 ;16 FEMA -1664 -DR -HI 97 044 EMW-2015413.02101 97067 EMW2015SS•00003 07 CO) ti t6H10004A G17H10004A G18HI0004A 'Audited as a major federal program for the fiscal year ended June 30, 2018, Federal Total Provided Program Federal Through to Award Amount Expenditures Subrecipients NIA S 208,262 $ 65,913 j— 65,913 NIA NIA WA NIA NIA NIA The accompanying notes are an integral part of this schedule. 6629,030 21,780 1.369,493 120,137 760,000 649,764 791,701 225,585 31,857 252,527 152,417 170,800 10,682 194,956 194,956 5 39,075,030 5 3,944,344 County of Hawaii, State of Hawaii NOTES TO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Fiscal Year Ended June 30, 2018 NOTE A - BASIS OF PRESENTATION The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activities of the County of Hawaii and its discretely presented component unit, the Department of Water Supply, under programs of the federal government for the fiscal year ended June 30, 2018. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the County of Hawai'i , it is not intended to, and does not present the financial position, changes in financial position, or cash flows of the County of Hawai'i. NOTE B - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Expenditures reported on the Schedule are reported on the cash basis of accounting. Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget Circular A-87, Cost Principles for State, Local and Indian Tribal Governments, or the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. NOTE C - INDIRECT COST RATE The County of Hawaii has elected not to use the 10 -percent de minimis indirect cost rate allowed under the Uniform Guidance. 23 PART III SCHEDULE OF FINDINGS AND QUESTIONED COSTS 24 County of Hawaii, State of Hawaii SCHEDULE OF FINDINGS AND QUESTIONED COSTS Fiscal Year Ended June 30, 2018 SECTION I - SUMMARY OF AUDITOR'S RESULTS Financial Statements Type of report the auditor issued on whether the financial statements audited were prepared in accordance with GAAP: Internal control over financial reporting: Material weakness(es) identified? Significant deficiency(ies) identified? Noncompliance material to financial statements noted? Federal Awards Internal control over major federal programs: Material weakness(es) identified? Significant deficiency(ies) identified? Type of auditor's report issued on compliance for major federal programs: Any audit findings disclosed that are required to be reported in accordance with 2 CFR 200.516(a)? Identification of major federal programs: CFDA Number 14.871 17.258/17.259/17.278 Dollar threshold used to distinguish between Type A and Type B programs: Auditee qualified as a low-risk auditee? SECTION II - FINANCIAL STATEMENT FINDINGS No matters were reported. Unmodified yes ✓_ no yes ✓ none reported . yes ✓ no yes _ no _ yes ✓ none reported Unmodified _ yes no Name of Federal Program or Cluster Section 8 Housing Choice Vouchers WIOA Cluster $1,172,251 1 yes SECTION Ili - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS No matters were reported. 25 no PART IV SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS (Provided by the County of Hawai`i) 26 County of Hawaii, State of Hawai'i STATUS REPORT Fiscal Year Ended June 30, 2018 No prior audit findings which apply under the current criteria of the Uniform Guidance were noted. 27 Appendix B: Civil Rights Certification Civil Rights Certification (Qualified PHAs) U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB Approval No. 2577-0226 Expires 02/29/2016 Civil Rights Certification Annual Certification and Board Resolution Acting on behalf of the Board of Commissioners of the Public Housing Agency (PHA) listed below, as its Chairman or other authorized PHA official, I approve the submission of the 5 -Year PHA Plan for the PHA of which this document is a part, and make the following certification and agreements with the Department of Housing and Urban Development (HUD) in connection with the submission of the public housing program of the agency and implementation thereof The PHA certifies that it will carry out the public housing program of the agency in conformity with title VI of the Civil Rights Act of 1964, the Fair Housing Act, section 504 of the Rehabilitation Act of 1973, and title II of the Americans with Disabilities Act of 1990, and will affirmatively further fair housing by examining their programs or proposed programs, identifying any impediments to fair housing choice within those program, addressing those impediments in a reasonable fashion in view of the resources available and working with local jurisdictions to implement any of the jurisdiction's initiatives to affirmatively further fair housing that require the PHA's involvement and by maintaining records reflecting these analyses and actions. Hawaii County Housing Agency H1002 PHA Name PHA Number/HA Code I hereby certify that all the information stated herein, as well as any information provided in the accompaniment herewith, is true and accurate Warning: HUD will prgsccute false claims and statements. Conviction may result in criminal and/or civil penalties, (18 U S.C. 1001, 1010, 1012, 31 U S.C. 3729, 3802) Name of Authorized Oficial Duane T. Hosaka Signature Title Housing Administrator Date APR 01 2020 Previous version is obsolete Page I of I form HUD -50077 -CR (2/2013) Appendix C: Certification by State or Local Official of PHA Plans Consistency with the Consolidated Pian Certification by State or Local Official of PHA Plans Consistency with the Consolidated Plan or State Consolidated Plan (All PHAs) I, U. S Department of Housing and L;rban Development Office of Public and Indian Housing OMB No. 2577-0226 Expires 2/29/2016 Certification by State or Local Official of PHA Plans Consistency with the Consolidated Plan or State Consolidated Plan Duane T. Hosaka , the Housing Administrator Official's Name Official's Title certify that the 5 -Year PHA Plan and/or Annual PHA Plan of the Hawaii County Housing Agency PHA Name is consistent with the Consolidated Plan or State Consolidated Plan and the Analysis of Impediments (AI) to Fair Housing Choice of the County of Hawaii Local Jurisdiction Name pursuant to 24 CFR Part 91. Provide a description of how the PHA Plan is consistent with the Consolidated Plan or State Consolidated Plan and the AI. The FY beginning 2020 5—year plan is consistent with the County of Hawaii's Consolidated flan. The Hawaii County Housing Agency and the Office of Housing and Community Development work in conjunction to address affordable housing needs using the Office of Housing and Community Development as a resource for HUD related housing programs. 1 hereby certify that all the information staled herein, as well as any inErmaticn provided in the accompaniment herewith, is true and accurate Warning: HUD will prosecute false claims and statements Conviction may result in cnmmal andlcr civil penalties (18 U S C 1001, 1010, 1012, 31 U S C 3729, 3802) Name of Authorized Official Signature Duane T. Hosaka Title Housing Administrator Date APR 01 2020 Page 1 of 1 form HUD -50077-5L (12/2014) Appendix D: Certifications of Compliance with PHA Plans and Related Regulations Certifications of Compliance with PHA Plans and Related Regulations (Standard, Troubled, HCV -Only, and High Performer PHAs) U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No. 2577-0226 Expires 02/29/2016 PHA Certifications of Compliance with the PHA Plan and Related Regulations including Required Civil Rights Certifications Acting on behalf of the Board of Commissioners of the Public Housing Agency (PHA) listed below, as its Chairman or other authorized PHA official if there is no Board of Commissioners, I approve the submission of the X S -Year and/or X Annual PHA Plan for the PHA fiscal year beginning 2020 , hereinafter referred to as" the Plan", of which this document is a part and make the following certifications and agreements with the Department of Housing and Urban Development (HUD) in connection with the submission of the Plan and implementation thereof 1. The Plan is consistent with the applicable comprehensive housing affordability strategy (or any plan incorporating such strategy) for the jurisdiction in which the PHA is located. 2. The Plan contains a certification by the appropriate State or local officials that the Plan is consistent with the applicable Consolidated Plan, which includes a certification that requires the preparation of an Analysis of Impediments to Fair Housing Choice, for the PHA's jurisdiction and a description of the manner in which the PHA Plan is consistent with the applicable Consolidated Plan. 3. The PHA has established a Resident Advisory Board or Boards, the membership of which represents the residents assisted by the PHA, consulted with this Resident Advisory Board or Boards in developing the Plan, including any changes or revisions to the policies and programs identified in the Plan before they were implemented, and considered the recommendations of the RAB (24 CFR 903.13). The PHA has included in the Plan submission a copy of the recommendations made by the Resident Advisory Board or Boards and a description of the manner in which the Plan addresses these recommendations. 4. The PHA made the proposed PIan and all information relevant to the public hearing available for public inspection at least 45 days before the hearing, published a notice that a hearing would be held and conducted a hearing to discuss the Plan and invited public comment. 5. The PHA certifies that it will carry out the Plan in conformity with Title VI of the Civil Rights Act of 1964, the Fair Housing Act, section 504 of the Rehabilitation Act of 1973, and title Il of the Americans with Disabilities Act of 1990. 6. The PHA will affirmatively further fair housing by examining their programs or proposed programs, identifying any impediments to fair housing choice within those programs, addressing those impediments in a reasonable fashion in view of the resources available and work with local jurisdictions to implement any of the jurisdiction's initiatives to affirmatively further fair housing that require the PHA's involvement and by maintaining records reflecting these analyses and actions. 7. For PHA Plans that includes a policy for site based waiting lists: • The PHA regularly submits required data to HUD's 50058 PIC/IMS Module in an accurate, complete and timely manner (as specified in PIH Notice 2010-25); • The system of site-based waiting lists provides for full disclosure to each applicant in the selection of the development in which to reside, including basic information about available sites; and an estimate of the period of time the applicant would likely have to wait to be admitted to units of different sizes and types at each site; • Adoption of a site-based waiting list would not violate any court order or settlement agreement or be inconsistent with a pending complaint brought by HUD; • The PHA shall take reasonable measures to assure that such a waiting list is consistent with affirmatively furthering fair housing; • The PHA provides for review of its site-based waiting list policy to determine if it is consistent with civil rights Iaws and certifications, as specified in 24 CFR part 903.7(c)(l). 8. The PHA will comply with the prohibitions against discrimination on the basis of age pursuant to the Age Discrimination Act of 1975. 9. The PHA will comply with the Architectural Barriers Act of 1968 and 24 CFR Part 41, Policies and Procedures for the Enforcement of Standards and Requirements for Accessibility by the Physically Handicapped. 10. The PHA will comply with the requirements of section 3 of the Housing and Urban Development Act of 1968, Employment Opportunities for Low -or Very -Low Income Persons, and with its implementing regulation at 24 CFR Part 135. 11. The PHA will comply with acquisition and relocation requirements of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 and implementing regulations at 49 CFR Part 24 as applicable. Page 1 oft form HUD -50077 -ST -HCV -HP (12/2014) 12. The PHA will take appropriate affirmative action to award contracts to minority and women's business enterprises under 24 CFR 5.105(a). 13 The PHA will provide the responsible entity or HUD any documentation that the responsible entity or HUD needs to carry out its review under the National Environmental Policy Act and other related authorities in accordance with 24 CFR Part 58 or Part 50, respectively. 14. With respect to public housing the PHA will comply with Davis -Bacon or HUD determined wage rate requirements under Section 12 of the United States Housing Act of 1937 and the Contract Work Hours and Safety Standards Act. 15. The PHA will keep records in accordance with 24 CFR 85.20 and facilitate an effective audit to determine compliance with program requirements. 16. The PHA will comply with the Lead -Based Paint Poisoning Prevention Act, the Residential Lead -Based Paint Hazard Reduction Act of 1992, and 24 CFR Part 35. 17. The PHA will comply with the policies, guidelines, and requirements of OMB Circular No. A-87 (Cost Principles for State, Local and Indian Tribal Governments), 2 CFR Part 225, and 24 CFR Part 85 (Administrative Requirements for Grants and Cooperative Agreements to State, Local and Federally Recognized Indian Tribal Governments). 18. The PHA will undertake only activities and programs covered by the Plan in a manner consistent with its Plan and will utilize covered grant funds only for activities that are approvable under the regulations and included in its Plan. 19. All attachments to the Plan have been and will continue to be available at all times and all locations that the PHA Plan is available for public inspection. All required supporting documents have been made available for public inspection along with the Plan and additional requirements at the primary business office of the PHA and at all other times and locations identified by the PHA in its PHA Plan and will continue to be made available at least at the primary business office of the PHA. 22. The PHA certifies that it is in compliance with applicable Federal statutory and regulatory requirements, including the Declaration of Trust(s). Hawaii County Housing Agency H1002 PHA Name X Annual PHA Plan for Fiscal Year 20 20 X 5 -Year PHA Plan for Fiscal Years 20 20 - 20 24 PHA Number/HA Code I hereby certify that all the information stated herein, as well as any information provided in the accompaniment herewith, is true and accurate Warning: HUD will prosecute false claims and statements. Conviction may result in criminal andfor civil penalties (18 U S.0 1001, 1010, 1012, 31 U.S C 3729, 3802) Name of Authorized Official Signature Title Chair, Hawaii County Housing Agency Date t$1\11 Page 2 of 2 form HUD -50077 -ST -HCV -HP (12/2014) Appendix E: Resident Advisory Board (RAB) Comments/Narrative Resident Advisory Board Meeting DRAFT FY 2020 PHA annual and 5 -year plan February 25, 2020 9:00 am -10:00 am Members Present: Malia Angay, Goldine Mehau, Serina Riveira, Deedra Ferreira, Michelle Marcos, Palani Emeliana, Crown Light, Lillian Kekaualua, Richard Spencer, Akalina Spencer, Deanine Cabatbat, Vernon Reiger, Paula Reiger, Dorothy Sheline, Jon Wakefield, Mario Makuakane, Angeline Krygier, Jessie Haa, Jacqueline Parker, Jenney Hardman, Wailani Gonsalves, Abigail Taleng, Hizson Tripp, Casarah Silva Exline, and Anthony Exline Staff Present: Desiree Moore, Kori Koike Smith, Kim Pacheco, and Arianne Alonzo Guest Speakers- Tanya Grebe, PhD-OHCD Grants Management, WIOA Denise Pacheco, American Job Center Hawaii Meeting Agenda I. Overview of PHA plans and purpose II. Recent purposed changes to waitlist preferences III. FSS action plan update and revisions IV. American Job Center Hawaii V. HireNet Tools for Job Seekers/Resume Writing Summary of Presentation 1. Introductions of staff and guest speakers 2. Summarized the purpose and importance of the RAB 3. Reviewed the background of the PHA annual and 5 -year plans 4. Reviewed purposed waitlist preference changes 5. Discussed the FSS action plan update 6. Tanya Grube, Phd spoke about the American Job Center and passed out brochures about services provided 7. Denise Pacheco discussed her role in assisting the American Job Center, resume writing, and HireNet tools. Comments by RAB members 1. A participant stated that after she signed up for HireNet she was receiving frequent "spam mailings" 6595skaks 2. A participant stated that she was having difficulty finding employment via the American Job Center/HireNet PHA Narrative The RAB meeting was effective in updating participants of goals, objectives, and progress of the PHA, upcoming changes to the waitlist preference and the FSS action plan. All members of the RAB were given copies of the PHA 5 -year and annual plans to take home. We encouraged RAB members to review the plans and provide public comment via sec8info@hawaiicountv.gov or to attend the public hearing scheduled for March 23, 2020 at 9:00 am. This meeting also provided members of the RAB with additional resources on the American Job Center, HireNet, and resume writing. 6595skaks RESIDENTIAL ADVISORY BOARD- OHCD PH • PHA 5 -year and Annual plan review • FSS updates Facilitator: Kori Koike Smith, Desiree Moore, Kim Pacheco. and Ari Alonzo Project: Date: Name: (Please Print) 9,7'&'/Z ..%1‹,),64,.1L. I WiNCL 1 ri •2 2s�� 6,011 N1ec1c- 11 S ` �! `✓t CtliVfl �1 y YGtYt� 2I2-j,.41C4 -C-�,c M-442-0 21 -kw Ritkki imfiago • L,6,/ `r "1 4 - nature: i4 A 5 -YEAR & ANNUAL PLAN FY 2021 r Meeting Date: February 25, 2020 at 9:00am Place/Room: OHCD conference room Phone: INEOr Email: 1 hep- �]�r`.11 V-aKDVAwb a . Ds •ao \.- W -i .A -Ns v 2c- Q6 . 11242,.` + Limon et/ .4.4,1 -2125-1 - ‘Q/a5/1.:-, r4 7 Si) 'kk z1/25/2z12,572v (^ yee/'l4Z 1JoM4I'Lo 10414lkaw r, CkCI iimmow evalfinami "PA fr)I Elk RESIDENTIAL ADVISORY BOARD- OHCD PHA 5 -YEAR & ANNUAL PLAN FY 2021 Project: • PHA 5 -year and Annual plan review I • FSS updates Meeting Date: Facilitator: Kori Koike Smith, Desiree Moore, Kim Pacheco, and Ari Alonzo Place/Room: February 25, 2020 at 9:00am OHCD conference room Name: (Please Print) Signature: Email: A\0 Tet1enc qrrriMEN [ter- 2125'2,-4«�_, L Appendix F: Family Self Sufficiency (FSS) Action Plan Office of Housing and Community Development FSS Action Plan for the Family Self -Sufficiency Program mu Nan McKay AND ASSOCIATES, INC" 1810 Gillespie Way, Suite 202 El Cajon, CA 92020 800.783.3100 www.nanmckay.com Copyright 2017 by Nan McKay & Associates, Inc. All rights reserved Permission to reprint granted only to the Public Housing Authority or Housing Agency that has purchased this plan from Nan McKay & Associates, Inc. This document may not be reprinted or distributed to any other person or entity other than the purchasing agency without the express written permission of Nan McKay & Associates, Inc. FSS Action Plan TABLE OF CONTENTS CHAPTER 1 THE FAMILY SELF-SUFFICIENCY PROGRAM AND THE FSS ACTION PLAN PART I: THE FAMILY SELF-SUFFICIENCY (FSS) PROGRAM AND FSS ACTION PLAN 1 1-I.A. OVERVIEW OF THE FAMILY SELF-SUFFICIENCY PROGRAM 1 1-I.B. APPLICABLE REGULATIONS 2 1-I.C. THE FAMILY SELF-SUFFICIENCY ACTION PLAN 2 PART II. REQUIREMENTS OF THE FSS ACTION PLAN 3 1-II.A. OVERVIEW 3 1-II.B. HUD APPROACH TO POLICY DEVELOPMENT 3 1-II.C. FSS ACTION PLAN DEVELOPMENT AND REVISION 4 Development of Action Plan [24 CFR 984.201(b) and (c)] 4 Single Action Plan [24 CFR 984.201(0] 4 Revision to the FSS Action Plan [24 CFR 984.201(c)(2)] 4 1-II.D. CONTENTS OF THE PLAN [24CFR 984.201(d)] 5 1-II.E. FAMILY DEMOGRAPHICS [24 CFR 984.201(d)(1)] 7 ' Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page TOC -1 Model FSS Action Plan 6:'1117 CHAPTER 2 PURPOSE, SCOPE, AND APPLICABILITY OF THE FAMILY SELF-SUFFICIENCY PROGRAM PART I: PURPOSE AND BASIC REQUIREMENTS OF THE FSS PROGRAM 3 2-I.A. PURPOSE 3 2-I.B. PROGRAM OBJECTIVES [24 CFR 984.102] 3 2 -LC. BASIC REQUIREMENTS OF THE FSS PROGRAM [24 CFR 984.104] 3 PART II: SCOPE OF THE FSS PROGRAM 5 2 -ILA. PHAS REQUIRED TO OPERATE AN FSS PROGRAM 5 Mandatory Minimum Program Size (MMPS) [24 CFR 984.105] 5 2-II.B. ESTIMATE OF PARTICIPATING FAMILIES [24 CFR 984.201(d)(2)] 8 2•II.C. ELIGIBLE FAMILIES FROM OTHER SELF-SUFFICIENCY PROGRAMS [24 CFR 984.201(d)(3)] 8 2-II.D. ELIGIBILITY OF A COMBINED PROGRAM [24 CFR 984.201(e)] 8 PART III: PROGRAM OPERATION 9 2-III.A. OVERVIEW 9 2-11I.B. PROGRAM IMPLEMENTATION DEADLINE 9 Voluntary Program [24 CFR 984.301(a)(1)] 9 Mandatory Program [24 CFR 984.301(a)(2)] 9 2-III.C. FULL ENROLLMENT AND DELIVERY OF SERVICE [24 CFR 984.301(a)(2)(ii)] 9 2-III.D. EXTENSION OF PROGRAM DEADLINES FOR GOOD CAUSE [24 CFR 984.301(a)(2)(iii)] 10 2-III.E. TIMETABLE FOR PROGRAM IMPLEMENTATION [24 CFR 984.201(d)(ii)] 10 PART IV: DEFINITIONS 11 2-IV.A. DEFINITIONS [24 CFR 984.103] 11 1: o Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page TOC -2 Model FSS Action PIan 611:`17 CHAPTER 3 PROGRAM ADMINISTRATION PART I. STAFFING, FEES AND COSTS, AND ON-SITE FACILITIES 2 3-I.A. OVERVIEW 2 3-I.B. PROGRAM ADMINISTRATION STAFF AND CONTRACTORS [24 CFR 984.301(b)] 2 3-I.C. ADMINISTRATIVE FEES AND COSTS 3 Public Housing FSS Program 3 Housing Choice Voucher FSS Program 3 3-I.D. SUPPORTIVE SERVICES FEES AND COSTS 4 Public Housing Supportive Services 4 Housing Choice Voucher Supportive Services 4 3-I.E. ON-SITE FACILITIES 4 PART II: PROGRAM COORDINATING COMMITTEE 5 3-II.A. OVERVIEW 5 3-II.B. PROGRAM COORDINATING COMMITTEE MEMBERSHIP 5 Required PCC Membership [24 CFR 984.202(b)(1)] 5 Recommended PCC Membership [24 CFR 984.202(b)(2)] 6 3-I1.C. ALTERNATIVE PCC COMMITTEE [24 CFR 984.202(c)] 6 CHAPTER 4 SELECTING AND SERVING FSS FAMILIES PART I. INCENTIVES, OUTREACH, AND ASSURANCE OF NONINTERFERENCE 3 4-I.A. OVERVIEW 3 4-I.B. INCENTIVES FOR PARTICIPATION [24 984.201(d)(5)] 3 4-I.C. OUTREACH EFFORTS [24 CFR 984.201(d)(6)(i)(ii)] 4 4-I.D. ASSURANCE OF NONINTERFERENCE WITH THE RIGHTS OF NONPARTICIPATING FAMILIES [24 CFR 984.201(d)(10)] 5 PART II. FAMILY SELECTION 7 4-II.A. OVERIVEW 7 4-I1.B. FSS SELECTION PREFERENCES 7 4-II.C. SELECTION FACTORS 8 Motivation Selection Factors [24 CFR 984.203(c)(1)] 8 Other Selection Factors 9 PART III. ACTIVITIES AND SUPPORT SERVICES 11 4-III.A. OVERVIEW 11 4-III.B. METHOD OF IDENTIFYING FAMILY SUPPORT NEEDS [24 CFR 984.201(d)(8)] 11 4-III.C. FSS ACTIVITIES AND SUPPORT SERVICES DESCRIPTION [24 CFR 984.201(d)(7)] 12 4-III.D. CERTIFICATION OF COORDINATION [24 CFR 984.201(d)(12)] 15 .4' Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page TOC -3 Model ESS Action Plan 6/1/17 CHAPTER 5 CONTRACT OF PARTICIPATION PART I: OVERVIEW AND FAMILY OBLIGATIONS 1 5-I.A. OVERVIEW 1 5-I.B. CONTENTS OF THE CONTRACT OF PARTICIPATION 2 Individual Training and Services Plan 2 5-I.C. FAMILY OBLIGATIONS 3 Compliance with Lease Terms 3 Employment Obligation [24 CFR 984.303 (b)(4)] 4 5-1.D. CONSEQUENCES OF NONCOMPLIANCE WITH THE CONTRACT 5 PART I1. CONTRACT SPECIFICATIONS 7 5-II.A. OVERIVEW 7 5-1I.B. CONTRACT TERM [24 CFR 984.303(c)] 7 Contract Extension [24 CFR 984.303(d)] 7 5-II.C. MODIFICATION OF THE CONTRACT 8 5-II.D. COMPLETION OF THE CONTRACT 9 5-II.E. TRANSITIONAL SUPPORTIVE SERVICE ASSISTANCE 9 5-II.F. TERMINATION OF THE CONTRACT 10 5-II.G. OPTION TO WITHHOLD OR TERMINATE SUPPORTIVE SERVICE AND HOUSING ASSISTANCE [24 CFR 984.303(b)(5)(i)1 11 5-I1.H. NULLIFICATION OF CONTRACT FOR UNAVAILABILITY OF SUPPORTIVE SERVICES [24 CFR 984.303(e)] 11 5-II.1. GRIEVANCE PROCEDURES 12 C Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page TOC -4 Model FSS Action Plan 6.01/17 CHAPTER 6 ESCROW ACCOUNT PART I. THE ESCROW ACCOUNT 1 6-I.A. OVERVIEW 1 6-1.B. CALCULATING THE FSS CREDIT AMOUNT 2 Determination of Family Rent and Total Tenant Payment 2 Increases in FSS Family Income [24 CFR 984.304] 2 Cessation of FSS Credit [24 CFR 984.305(b)(3)] 2 6-I.C. DISBURSEMENT OF FSS ACCOUNT FUNDS 3 Disbursement at Completion of Contract [24 CFR 984.305(c)(1)] 3 Disbursement before Expiration of Contract Term 3 Verification of Family Certification at Disbursement 4 Succession to FSS Account [24 CFR 984.305(d)] 4 6-I.D. USE OF FSS ACCOUNT FUNDS FOR HOMEOWNERSHIP 5 6-I.E. FORFEITURE OF FSS ACCOUNT FUNDS 6 Treatment of Forfeited FSS Account Funds 6 PART II. ESCROW FUND ACCOUNTING AND REPORTING 7 6-II.A. OVERVIEW 7 6-II.13. ACCOUNTING FOR FSS ACCOUNT FUNDS 7 Proration of Investment Income [24 CFR 984.305(a)(2)(ii)] 7 Reduction of Amounts Due by FSS Family [24 CFR 984.305(a)(2)(iii)] 7 6 -ILC. REPORTING ON THE FSS ACCOUNT 8 CHAPTER 7 PORTABILITY IN HOUSING CHOICE VOUCHER FSS PROGRAMS PART I: PORTABILITY IN THE FSS PROGRAM 1 7-I.A. OVERVIEW 1 7-1.13. DEFINITIONS 2 7 -LC. RESIDENCY REQUIREMENTS 2 7-I.D. CONTRACT OF PARTICIPATION 3 Continued Participation in the FSS program of the Initial PHA 3 PART II: THE EFFECTS OF PORTABILITY ON FSS REGULATIONS AND POLICY 4 7-II.A. OVERVIEW 4 7-II.13. PORTABILITY AND THE ESCROW ACCOUNT [24 CFR 984306(e)] 4 7-II.C. PROGRAM TERMINATION, LOSS OF FSS ACCOUNT, AND TERMINATION OF SECTION 8 ASSISTANCE 4 ® Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page TOC -5 Model FSS Action Plan 6/1:17 0 Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page TOC -6 Model FSS Action Plan 6/1117 Chapter 1 THE FAMILY SELF-SUFFICIENCY PROGRAM AND THE FSS ACTION PLAN INTRODUCTION This chapter provides an overview of the family self-sufficiency (FSS) program and FSS action plan, including the purpose, organization, and required contents of the FSS action plan. Part I: The Family Self -Sufficiency FSS) Program and FSS Action Plan: This part provides an overview of the family self-sufficiency program and the purpose of the FSS action plan. Part II: Requirements of the FSS Action Plan: This part covers action plan requirements, including development, revision, and contents of the action plan. It also contains information on family demographics, which is part of the required contents of the action plan. PART I: THE FAMILY SELF-SUFFICIENCY (FSS) PROGRAM AND FSS ACTION PLAN 1-I.A. OVERVIEW OF THE FAMILY SELF-SUFFICIENCY PROGRAM The origins of the FSS program are in two pilot projects implemented in 1986 and 1990, Project Self -Sufficiency and Operation Bootstrap, respectively. These projects were set up to test self- sufficiency programs for families with housing subsidies, and both demonstrated that families needed essential services in order to move toward economic self-sufficiency. These services include child care, transportation, medical care, and long-term education and training. In the wake of the successful demonstration of these projects, family self-sufficiency became one of the initiatives under the Homeownership and Housing Opportunities for People Everywhere (HOPE) program enacted in 1990, and the FSS program was subsequently created under the National Affordable Housing Act the same year. FSS built upon and refined both Project Self -Sufficiency and the bootstrap program. It remained a voluntary program in 1991 and 1992, but became mandatory in 1993 for any new increments of funding issued to Public Housing Agencies (PHAs). The 1993 regulations were further modified by the Quality Housing and Work Responsibility Act of 1998 (QHWRA). The purpose of the FSS program is to coordinate housing assistance with public and private resources to enable assisted families to achieve economic self-sufficiency. The purpose and basic requirements of the FSS program are further elaborated upon in Chapter 2. This family self-sufficiency program is administered by the Office of Housing & Community Development (OHCD) for the jurisdiction of the County of Hawaii. : Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 1-1 Model FSS Action Plan 611117 1-I.B. APPLICABLE REGULATIONS Applicable regulations for public housing and HCV FSS programs include: 24 CFR Part 5: General Program Requirements 24 CFR Part 8: Nondiscrimination 24 CFR Part 902: Public Housing Assessment System 24 CFR Part 903: Public Housing Agency Plans 24 CFR Part 945: Designated Housing 24 CFR Part 960: Public Housing Admission and Occupancy Policies 24 CFR Part 965: PHA -Owned or Leased Projects ---General Provisions 24 CFR Part 966: Public Housing Lease and Grievance Procedures 24 CFR Part 982: Section 8 Tenant -Based Assistance: Housing Choice Voucher Program 24 CFR Part 984: Section 8 and Public Housing Family Self -Sufficiency Program 1-I.C. THE FAMILY SELF-SUFFICIENCY ACTION PLAN The family self-sufficiency (FSS) action plan is required by HUD. The purpose of the FSS action plan is to establish policies for carrying out the family self-sufficiency program in a manner consistent with HUD requirements and local goals and objectives contained in the PHA's Agency Plan. This FSS action plan is a supporting document to the PHA Agency Plan, and is available for public review as required by 24 CFR Part 903. This family self-sufficiency action plan is set forth to define the PHA's local policies for operation of the program in the context of federal laws and regulations. All issues related to FSS not addressed in this document are governed by such federal regulations, HUD handbooks and guidebooks, notices, and other applicable laws. The policies in this FSS action plan have been designed to ensure compliance with the consolidated ACC and all HUD -approved applications for program funding. The PHA is responsible for complying with all changes in HUD regulations pertaining to the FSS program. If such changes conflict with this plan, HUD regulations will take precedence. Administration of the FSS program and the functions and responsibilities of PHA staff shall be in compliance with the PHA's personnel policy and HUD's family self-sufficiency regulations, as well as all public housing and HCV regulations, in addition to federal, state, and local fair housing laws and regulations. Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 1-2 Model FSS Action Plan 611/17 PART II. REQUIREMENTS OF THE FSS ACTION PLAN 1-II.A. OVERVIEW A PHA must have a HUD -approved action plan before implementing an FSS program, regardless of whether the FSS program is a mandatory or voluntary program. Further, this action plan must comply with the requirements specified for the plan in the regulations [24 CFR 984.201(a)]. The regulatory requirements dealing specifically with the FSS action plan itself largely involve the development, revision, and required contents of the action plan. This part covers those requirements. 1-II.B. HUD APPROACH TO POLICY DEVELOPMENT In developing policy for the FSS action plan, PHAs need to be aware of the distinction HUD makes between mandatory and discretionary policies. Mandatory policies are those driven by legislation, regulations, current handbooks, notices, and legal opinions. Discretionary policies consist of those developed for areas in which the PHA has regulatory discretion, or with regard to optional, nonbinding guidance including guidebooks, notices that have expired, and recommendations from individual HUD staff. HUD expects PHAs to develop policies and procedures that are consistent with mandatory regulations and to make clear the optional policies the PHA has adopted. The PHA's FSS action plan is the foundation of those policies and procedures for the FSS program. HUD's directions require PHAs to make policy choices that provide guidance to staff and consistency to program applicants and participants. Following HUD guidance, even though it is not mandatory, provides a PHA with a "safe harbor." HUD has already determined that the recommendations and suggestions it makes are consistent with mandatory policies. If a PHA adopts an alternative strategy, it must make its own determination that the alternative approach is consistent with legislation, regulations, and other mandatory requirements. There may be very good reasons for adopting a policy or procedure that is different than HUD's safe harbor, but PHAs should carefully consider those decisions. Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 1-3 Model FSS Action Plan 6/1117 1 -ILC. FSS ACTION PLAN DEVELOPMENT AND REVISION Development of Action Plan [24 CFR 984.201(b) and (c)] When developing an FSS action plan, a PHA must do so in consultation with the chief executive officer of the applicable unit of general local government and the program coordinating committee (PCC). In addition, a PHA that is establishing its FSS program must submit an action plan to HUD for approval within 90 days after the PHA receives notice from HUD of approval of the PHA's application for funding that establishes the obligation to operate an FSS program. This deadline is required unless the dates are extended by HUD for good cause. For voluntary FSS programs, the PHA must submit its action plan and obtain HUD approval of the plan before it can implement the FSS program. This includes a voluntary program established because the PHA chose to implement an FSS program that exceeds the minimum size for a mandatory program (see Section 2 -ILA. for a discussion of mandatory versus voluntary FSS programs). Single Action Plan [24 CFR 984.201(1)1 PHAs implementing both a Section 8 FSS program and a public or Indian housing FSS program may submit one action plan. In cases where the PHA decides to submit one plan for more than one program, the policies contained in the action plan would apply to both programs. PHA Policy The PHA is implementing a housing choice voucher FSS program only and will submit one action plan. Revision to the FSS Action Plan [24 CFR 984.201(c)(2)1 Following HUD's initial approval of the action plan, no further approval of the action plan is required unless the PHA proposes to make policy changes to the action plan or increase the size of a voluntary program, or to revise the FSS action plan as needed to comply with changes in HUD regulations. The PHA must submit any changes to the action plan to HUD for approval. PHA Policy The PHA will review and update the action plan at least once a year, and more often if needed, to reflect changes in regulations, PHA operations, or when needed to ensure staff consistency in operation. ." Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 1-4 Model FSS Action Plan 6/1117 1-H.D. CONTENTS OF THE PLAN [24CFR 984.201(d)] HUD regulations state that there are several components that must be included in the FSS action plan. At a minimum, the action plan must cover the policies and procedures of the PHA for operation of a local FSS program as follows: Family demographics, including a description of the number, size, characteristics, and other demographics such as racial and ethnic data, in addition to the supportive service needs of the families expected to participate in the program. (Chapter 1) Estimate of participating families, which means the number of families which can reasonably be expected to receive supportive services under the FSS program. (Chapter 2) Eligible families from any other local self-sufficiency program who are expected to agree to executing an FSS contract of participation. (Chapter 2) • A statement of the PHA's FSS family selection procedures, including a description of how the procedures ensure that families are selected without regard to race, color, religion, disability, sex, familial status, or national origin. (Chapter 4) • A description of the incentives that the PHA intends to offer to families to encourage participation in the FSS program (an incentives plan), including the establishment of the escrow account. (Chapter 4) Outreach efforts, which include a description of the PHA's efforts to recruit eligible families, the actions the PHA will take to ensure that both minority and nonminority groups are informed about the FSS program, and how the PHA will make this information known. (Chapter 4) A description of the FSS activities and supportive services to be provided by both public and private resources to FSS families, and identification of these public and private resources. (Chapter 4) A description of the PHA's method for identifying family support needs, including how the PHA will identify the needs and deliver the services. (Chapter 4) A description of the PHA's policies regarding program termination or withholding of services on the basis of a family's failure to comply with the FSS contract, and available grievance procedures. (Chapter 5) Assurances of noninterference with rights of non -participating families which state that a family's election to not participate in the FSS program will not affect the family's admission to the public housing or HCV program, nor will it affect their right to occupancy in accordance with its lease. (Chapter 4) C Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 1-5 Model FSS Action Plan 611117 Timetable for program implementation, including the schedule for filling FSS slots with eligible families. (Chapter 2) Certification of coordination, which is a certification that the development of services and activities under the FSS program has been coordinated with the Workforce Investment Act (formerly JTPA), Workforce Investment Board and One Stop Centers (formerly JOBS program), and any other relevant employment, child care, transportation, training, and education programs in the applicable area, and that implementation will continue to be coordinated, in order to avoid duplication of services and activities. (Chapter 4) Optional additional information, which involves such other information that would help HUD determine the soundness of the PHA's proposed FSS program. (All Chapters) Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 1-6 Model ESS Action Plan 611117 1-II.E. FAMILY DEMOGRAPHICS [24 CFR 984.201(d)(1)] As part of the required contents of the FSS action plan, family demographics of the housing choice voucher and public housing program participants serve to provide a description of the number, size, characteristics, and other descriptive data (including racial and ethnic data of those participants). These data may later be used to help the housing authority and the program coordinating committee (PCC) to identify supportive service needs of the families expected to participate in the FSS program. Housing Choice Voucher/ Public Housing Total Families Percent of Total All Families 2201 100% Single 879 40% Female HOI3 1580 72% Male HOH 619 28% Race White 1224 56% Black/African American 133 6% American Indian/Alaska Native 241 11% Asian 456 21% Native Hawaiian/Other Pacific Islander 1305 59% Ethnicity . Hispanic or Latino 588 27% Not Hispanic or Latino 1847 84% Income Extremely Low -Income 1256 57% Very Low -Income 366 17% Low -Income 151 7% Income from Wages 848 39% Income from TANF 276 13% Income from SSI 1216 555 _Number of Children 0 1089 49% 1-2 318 14% 3-4 145 7% 5 or more 80 4% Total Number of Family Members 1-2 1247 57% 3-4 543 25% Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 1-7 Model FSS Action Plan 6/ 1 / 17 5 or more 411 19% Persons with Disabilities HOH Person w/ Disabilities (HUD) 941 43% Family Members w/ Disabilities 227 IO% C Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 1-8 Model FSS Action Plan 61 117 Chapter 2 PURPOSE, SCOPE, AND APPLICABILITY OF THE FAMILY SELF-SUFFICIENCY PROGRAM INTRODUCTION This chapter contains information about the FSS program's purpose, size, and measurable objectives as well as information on program operation. This includes potential participant demographics, the program timetable, the number of families to be served, and the size of the Public Housing Agency's (PHA) voluntary FSS program. This chapter also contains definitions of the key terms in this FSS action plan. Part I: The Purpose and Basic Requirements of the FSS program: This part includes a description of the purpose of the FSS program on a national level ---its intent, goal, and major strategies. Part I1: The Scope of the FSS program: This part contains information about the size of the PHA's FSS program, an estimate of participating families, eligible families from other self-sufficiency programs, and eligibility for combined FSS programs. Part III: Program Operation: This part specifies the requirements for FSS program operation, including the deadlines for program start-up and when the PHA is expected to have attained full enrollment. Part IV: The Definitions of Terms Used in the PHA's FSS program: This section contains both HUD and PHA definitions for terms used in this policy document. Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 2-1 Model FSS Action Plan 1211.11 Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 2-2 Model FSS Action Plan 12.1:1 I PART I: PURPOSE AND BASIC REQUIREMENTS OF THE FSS PROGRAM 2-I.A. PURPOSE The purpose of the family self-sufficiency (FSS) program is to promote the development of local strategies to coordinate the use of public housing assistance and housing assistance under the housing choice voucher program with public and private resources enabling families eligible to receive assistance under these programs to achieve economic independence and self-sufficiency [984.101(a)(1)]. In addition to this broader national goal of the FSS program, the PHA also establishes a local goal consistent with the PHA's mission statement to serve as a guide for establishing policy and implementing the FSS program. PHA Policy The PHA's goal in operating an FSS program is to match housing -assisted families with existing services so that they may reduce their dependency on housing, welfare, and other government subsidies and may achieve self-sufficiency defined as completion of the contract of participation. 2-I.B. PROGRAM OBJECTIVES [24 CFR 984.102] In order to reach the FSS national program goal, HUD has defined its FSS program objective as to reduce the dependency of low-income families on welfare assistance and on Section 8, public, or any federal, state, or local rent or homeownership subsidies. Under the FSS program, low- income families are provided opportunities for education, job training, counseling, and other forms of social service assistance while living in assisted housing so that they may obtain the education, employment, and business and social skills necessary to achieve self-sufficiency. As with the goals of the program, FSS program objectives are defined on the national level through FSS regulation, and on the local level by PHA policy. PHA Policy On the local level, the PHA will achieve the national program objective by offering low- income families services, or referring low-income families to services that provide education, training, and other forms of support so that families may achieve self- sufficiency as defined in Section 2-I.A. of this document. 2-I.C. BASIC REQUIREMENTS OF THE FSS PROGRAM [24 CFR 984.104] An FSS program established under 24 CFR Part 984 must operate in conformity with the regulations and this FSS action plan (as required in 24 CFR 984.201), provide comprehensive supportive services (as defined in 24 CFR 984.103), and operate in compliance with nondiscrimination and equal opportunity requirements. ® Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 2-3 Model FSS Action Plan 12/1,11 r Copyright 2011 b) Nan McKay & Associates Unlimited copies may be made for internal use. Page 2-4 Model FSS Action Plan 12/1.1 PART II: SCOPE OF THE FSS PROGRAM 2-II.A. PHAS REQUIRED TO OPERATE AN FSS PROGRAM Each PHA that received funding for public housing units under the FY 1991 and FY 1992 FSS incentive award competitions must operate a public housing FSS program. Each PHA that received funding for Section 8 rental certificates or vouchers under the combined FY 199111992 FSS incentive award competition also must operate a Section 8 FSS program. In addition, unless the PHA receives an exemption under 24 CFR 984.105, each PHA for which HUD reserved funding (budget authority) for additional rental certificates or vouchers in FY 1993 through October 20, 1998, must operate a Section 8 FSS program. Each PHA for which HUD reserved funding (budget authority) to acquire or construct additional public housing units in FY 1993 through October 20, 1998, must operate a public housing FSS program as well. Mandatory Minimum Program Size (MMPS) [24 CFR 984.105] PHAs that must operate an FSS program under 24 CFR 984.101 are subject to a minimum program size requirement. In public housing, a PHA's FSS program minimum program size is determined by adding the total number of public housing units reserved in FY 1991 and FY 1992 under the FSS incentive award competitions to the number of public housing units reserved in FY 1993 through October 20, 1998, and subtracting the number of families that have graduated from the PHA's public housing FSS program on or after October 21, 1998, by fulfilling their FSS contract of participation obligations. In the housing choice voucher program, a PHA's FSS program minimum program size is determined by adding the number of HCV program units reserved under the combined FY 1991/1992 FSS incentive award competition to the number of additional rental voucher units reserved in FY 1993 through October 20, 1998, (not including the renewal of funding for units previously reserved) then subtracting the units that are excluded from minimum program size and subtracting the number of families who have graduated from the PHA's Section 8 FSS program on or after October 21, 1998, by fulfilling their contract of participation obligations. Further, when determining the Section 8 FSS program size for funding reserved in FY 1993 through October 20, 1998, the PHA must exclude funding for families affected by termination, expiration, or owner opt -out under Section 8 project -based programs; funding for families affected by demolition or disposition of a public housing project or replacement of a public housing project; funding for families affected by conversion of assistance from the Section 23 leased housing or housing assistance payments programs to the housing choice voucher program; funding for families affected by the sale of a HUD -owned project; and funding for families affected by the prepayment of a mortgage or voluntary termination of mortgage insurance. '1` Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 2-5 Model FSS Action Plan 12:1'11 PHA Minimum Program Size The PHA has no mandatory minimum program size requirement and operates a voluntary FSS program. Maintaining Mandatory Minimum Program Size Although the discretion to do so ultimately rests with the PHA, mandatory minimum program size can decrease as FSS participants graduate. Per the regulation, for each family that graduates from the program by fulfilling its FSS contract of participation on or after October 21, 1998, the mandatory minimum program size for a PHA's public housing or housing choice voucher FSS program is reduced by one slot. However, If an FSS slot is vacated by a family that has not completed its FSS contract of participation obligations, the slot must be filled by a replacement family which has been selected in accordance with the FSS family selection procedures [24 CFR 984.105(b)(3)]. PHA Policy The PHA has no mandatory minimum program size and will increase the voluntary program size by one for each reduction to maintain an FSS program size of no more than 75. Option to Operate Larger FSS Program A PHA may choose to operate an FSS program of a larger size than the minimum required by HUD [24 CFR 984.105(a)(3)]. PHA Policy The PHA has no mandatory minimum program size and operates a voluntary FSS program of no more than seventy-five (75) families. .• Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 2-6 Model FSS Action Plan 12;'1.11 Exception to Program Operation C24 CFR 984.105(c)J The requirement to establish and carry out a public housing or a housing choice voucher FSS program may be waived with approval from HUD. In order to waive the requirement, the PHA must provide a certification to HUD that the establishment and operation of an FSS program is not feasible because of a lack of accessible supportive services funding, including lack of the availability of programs under JTPA or JOBS; a lack of funding for reasonable administrative costs; a lack of cooperation by other units of state or local government; or a lack of interest in participating in the FSS program on the part of eligible families. An exception will not be granted if HUD determines that local circumstances do not preclude the PHA from effectively operating an FSS program that is smaller than the minimum program size. Reduction in Program Size Rather than a full exception to program operation, a PHA may also be permitted to operate a public housing or a housing choice voucher FSS program that is smaller than the minimum program size. As with the full exception, HUD may grant the PHA such a partial exception if the PHA provides to HUD a certification that the operation of an FSS program of the minimum program size is not feasible because of a decrease in or lack of accessible supportive services [24 CFR 984.105(d)]. Expiration of Exception The approval for a full or partial exception to the FSS minimum program size requirement expires three years from the date of HUD approval of the exception. If a PHA seeks to continue an exception after its expiration, the PHA must submit a new request and a new certification to HUD for consideration [24 CFR 984.105(e)]. 51; Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 2-7 Model FSS Action Plan 12.' 1111 2-II.B. ESTIMATE OF PARTICIPATING FAMILIES [24 CFR 984.201(d)(2)] The PHA must state the number of eligible FSS families who can reasonably be expected to receive supportive services under the FSS program based on available and anticipated federal, tribal, state, local, and private resources Estimate of Eligible Families Seventy-five (75) eligible FSS families can reasonably be expected to receive supportive services under the FSS program, based on available and anticipated federal, tribal, state, local, and private resources. 2-II.C. ELIGIBLE FAMILIES FROM OTHER SELF-SUFFICIENCY PROGRAMS [24 CFR 984.201(d)(3)] If applicable, the PHA must enter the number of families, by program type, who are participating in any other local housing self-sufficiency program who are expected to agree to execute an FSS contract of participation. PHA Policy The PHA does not operate other self-sufficiency programs and therefore no additional families from other programs are expected to execute an FSS contract of participation. 2 -ILD. ELIGIBILITY OF A COMBINED PROGRAM [24 CFR 984.201(e)] A PHA that wishes to operate a joint FSS program with other PHAs may combine its resources with one or more PHAs to deliver supportive services under a joint action plan that will provide for the establishment and operation of a combined FSS program that meets the requirements of this part. PHA Policy The PHA will not combine its resources with any other PHA to deliver support services, have a joint action plan, or establish or operate a combined FSS Program. C Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 2-8 Model FSS Action Plan 1211 11 PART III: PROGRAM OPERATION 2-III.A. OVERVIEW Federal regulations specify requirements for FSS program operation regarding deadlines for program start-up and when the PHA is expected to have attained full enrollment. A timetable illustrating when the PHA intends to meet these deadlines is included as part of the required contents of the action plan. 2-III.B. PROGRAM IMPLEMENTATION DEADLINE The deadlines for program implementation differ depending on whether the FSS program is voluntary or mandatory. Voluntary Program [24 CFR 984.301(a)(1)] There is no deadline for implementation of a voluntary program. However, a voluntary program may not be implemented before the requirements specified in 24 CFR 984.201 have been satisfied (see Sections 1-II.A.--1-II.D.). Mandatory Program [24 CFR 984.301(a)(2)] For mandatory FSS programs, operation of a local FSS program must begin within 12 months of HUD's approval of funding that establishes the obligation to operate an FSS program. Operation means that activities such as outreach, participant selection, and enrollment have begun. Full delivery of the supportive services to be provided to the total number of families required to be served under the program need not occur within this 12 months, but must occur within two years (see Section 2-III.C.). 2-III.C. FULL ENROLLMENT AND DELIVERY OF SERVICE [24 CFR 984.301(a)(2)(ii)] Unless the PHA is implementing a voluntary FSS program, the PHA must have completed enrollment of the total number of families required to be served under the program (based on the minimum program size), and must have begun delivery of the supportive services within two years from the date of notification of approval of the application for new public housing units for a public housing FSS program, new rental certificates or rental vouchers for a Section 8 FSS program, or HUD's approval of funding that establishes the obligation to operate an FSS program. a: Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 2-9 Model FSS Action Plan 12'1 11 2 -IIID. EXTENSION OF PROGRAM DEADLINES FOR GOOD CAUSE [24 CFR 984.301(a)(2)(iii)] HUD may extend the deadline for program implementation if the PHA requests an extension and HUD determines that despite best efforts on the part of the PHA, the development of new public housing units will not occur within the required deadlines, the commitment by public or private resources to deliver supportive services has been withdrawn, the delivery of such services has been delayed, or other local circumstances warrant an extension of the required deadlines. 2-III.E. TIMETABLE FOR PROGRAM IMPLEMENTATION [24 CFR 984.201(d)] A timetable for implementation of the FSS program is part of the required contents of the FSS action plan. The timetable must comply with the requirements in 24 CFR 984.301 (see Section 2 - including the schedule for filling FSS slots with eligible FSS families. PHA Policy The PHA implemented its FSS program in July 1, 2004 and has met its former timetable deadlines. The PHA implemented its FSS program according to the following timetable: Activity Month and Date Establish PCC 4/28/2004 Conduct Program Needs Assessment N/A Resource Identification 5/20/2004 Establish Policies 7/1/2004 Design Service Delivery 3/16/2004 Develop Administrative Procedures 7/1/2004 Begin Service Delivery 7/1/2004 Conduct Outreach 4/30/2004 Conduct Orientations 6/1/2004 Conduct Individual Needs Assessment 8/1/2004 Begin Contracting 8/I/2004 Complete Contracting N/A Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 2-10 Model FSS Action Plan 1211'11 PART IV: DEFINITIONS 2-IV.A. DEFINITIONS [24 CFR 984.103] The terms 1937 Act, fair market rent, HUD, low-income family, public housing, public housing agency (PHA), secretary, and Section 8, as used in this document are defined in the 24 CFRPart5. The term very long -income family is defined in 24 CFR 813.102 and 24 CFR 913.102. The terms used in this document have the following definitions as defined by 24 CFR 984.103 and this family self-sufficiency action plan. Certification means a written assertion based on supporting evidence, provided by the FSS family or the PHA, which must be maintained by the PHA in the case of the family's certification, or by HUD in the case of the PHA's certification; made available for inspection by HUD, the PHA, and the public, as appropriate; and be deemed to be accurate, unless the secretary or the PHA determines otherwise after inspecting the evidence and providing due notice and opportunity for comment. Chief executive officer (CEO) means the CEO of a unit of general local government who is the elected official or the legally designated official having primary responsibility for the conduct of that entity's governmental affairs. Contract of participation (COP) means a contract in a form approved by HUD, entered into between a participating family and a PHA operating an FSS program that sets forth the terms and conditions governing participation in the FSS program. The contract of participation includes all individual training and services plans entered into between the PHA and all members of the family who will participate in the FSS program, and which plans are attached to the contract of participation as exhibits. For additional detail, see 24 CFR 984.303. Earned income means income or earnings included in annual income from wages, tips, salaries, other employee compensation, and self-employment. Earned income does not include any pension or annuity, transfer payments, any cash or in-kind benefits, or funds deposited in or accrued interest on the FSS escrow account established by a PHA on behalf of a participating family. Effective date of contract of participation means the first day of the month following the month in which the FSS family and the PHA entered into the contract of participation. Eligible families for the public housing FSS program means current residents of public housing, and for the housing choice voucher FSS program, means current housing choice voucher program participants. Eligible families also include current residents of public housing and participants in the housing choice voucher program who are participants in other local self- sufficiency programs. Enrollment means the date that the FSS family entered into the contract of participation with the PHA. Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal usc. Page 2-11 Model FSS Action Plan 12/1'11 11 Family self-sufficiency program or FSS program means the program established by a PHA within its jurisdiction to promote self-sufficiency among participating families, including the provision of supportive services to these families, as authorized by section 23 of the 1937 Act. FSS account means the FSS escrow account authorized by section 23 of the 1937 Act. FSS credit means the amount credited by the PHA to the participating family's FSS account. FSS family or participating family means a family that resides in public housing or receives assistance under the rental voucher programs that elects to participate in the FSS program and whose designated head of the family has signed the contract of participation. FSS -related service program means any program, publicly or privately sponsored, that offers the kinds of supportive services described in the definition of supportive services. FSS slots refer to the total number of public housing units or the total number of rental vouchers that comprise the minimum size of a PHA's respective public housing FSS program or HCV FSS program. FY means federal fiscal year (starting with October 1, and ending September 30, and designated by the calendar year in which it ends). Head of FSS family means the adult member of the FSS family who is the head of the household for purposes of determining income eligibility and rent. Housing subsidies means assistance to meet the costs and expenses of temporary shelter, rental housing, or homeownership, including rent, mortgage, or utility payments. Individual training and services plan (ITSP) means a written plan that is prepared for the head of the FSS family and each adult member of the FSS family who elects to participate in the FSS program, by the PHA in consultation with the family member, and which sets forth the supportive services to be provided to the family member, the activities to be completed by that family member, and the agreed upon completion dates for the services and activities. Each ITSP must be signed by the PHA and the participating family member, and is attached to and incorporated as part of the contract of participation. An ITSP must be prepared for the head of the FSS family. JTPA means the Job Training Partnership Act (29 U.S.C. 1579(a)) now known as the Workforce Investment Act or WIA. Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 2-12 Model FSS Action Plan 12.1111 Knowledgeable professional PHA Policy Knowledgeable professional means a person who is knowledgeable about the situation, competent to render a professional opinion, and is not in a position to gain, monetarily or otherwise, from the PHA FSS program decision in the area to which they are certifying. Participating family is defined as FSS family in this section. Program coordinating conunittee (PCC) means the committee described in 24 CFR 984.202. Public housing means housing assisted under the 1937 Act, excluding housing assisted under Section 8 of the 1937 Act. Self-sufficiency means that an FSS family is no longer receiving Section 8, public, or Indian housing assistance, or any federal, state, or local rent or homeownership subsidies or welfare assistance. Achievement of self-sufficiency, although an FSS program objective, is not a condition for receipt of the FSS account funds. Supportive services mean those appropriate services that a PHA will make available or cause to be made available to an FSS family under a contract of participation. These may include child care of a type that provides sufficient hours of operation and serves an appropriate range of ages; transportation necessary to enable a participating family to receive available services or to commute to their places of employment; remedial education; education for completion of secondary or post -secondary schooling; job training, preparation, and counseling; job development and placement; and follow-up assistance after job placement and completion of the contract of participation; substance/alcohol abuse treatment and counseling; training in homemaking and parenting skills; household management; money management; counseling regarding homeownership or opportunities available for affordable rental and homeownership in the private housing market (including information on an individual's rights under the Fair Housing Act) and money management; and any other services and resources, including case management and reasonable accommodations for individuals with disabilities, that the PHA may determine to be appropriate in assisting FSS families to achieve economic independence and self-sufficiency. Unit size or size of unit refers to the number of bedrooms in a dwelling unit. Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 2-13 Model FSS Action Plan 12/1; i Welfare assistance means (for purposes of the FSS program only) income assistance from federal or state welfare programs and includes only cash maintenance payments designed to meet a family's ongoing basic needs. Welfare assistance does not include nonrecurrent, short-term benefits that are designed to deal with a specific crisis situation or episode of need, or are not intended to meet recurrent or ongoing needs and will not extend beyond four months; work subsidies (i.e., payments to employers or third parties to help cover the costs of employee wages, benefits, supervision, and training); supportive services such as child care and transportation provided to families who are employed; refundable earned income tax credits; contributions to, and distributions from, individual development accounts under TANF; services such as counseling, case management, peer support, child care information and referral, transitional services, job retention, job advancement and other employment-related services that do not provide basic income support; transportation benefits provided under a Job Access or Reverse Commute project, pursuant to section 404(k) of the Social Security Act, to an individual who is not otherwise receiving assistance; amounts solely directed to meeting housing expenses; amounts for health care; food stamps and emergency rental and utilities assistance; and SSI, SSDI, or social security. Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 2-14 Model FSS Action Plan 12/1.'11 Chapter 3 PROGRAM ADMINISTRATION INTRODUCTION This chapter discusses administrative policies and practices as they are relevant to the activities covered in this plan. The policies and practices are discussed in two parts: Part I: Staffing, Fees and Costs, and On -Site Facilities: This part describes identifying appropriate staff and contractors to operate the FSS program and provide the necessary direct services to FSS families. In addition, it describes how administrative fees, costs, and supportive services will be funded, and defines the use of on-site facilities. Part II: The Program Coordinating Committee: This part covers the establishment of a program coordinating committee (PCC), which is a regulatory requirement for the FSS program. It describes required and recommended PCC membership, in addition to the option for an alternative committee. a Copyright 2014 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 3-1 Model FSS Action Plan 9/1,14 PART I. STAFFING, FEES AND COSTS, AND ON-SITE FACILITIES 3 -LA. OVERVIEW Several functions of program administration are crucial to running an FSS program. A Public Housing Agency (PHA) may need to employ a program coordinator, or decide to contract with another organization to administer the program. In addition to staffing issues, PHAs should understand how program funding and expenses work in order to keep the program running smoothly. Finally, PHAs need to sort out whether and how to make common areas or unoccupied units to provide supportive services. 3-I.B. PROGRAM ADMINISTRATION STAFF AND CONTRACTORS [24 CFR 984.301(b)] PHAs have the choice between hiring their own staff and contracting with an outside organization to administer their FSS program. If the PHA should choose to employ its own staff, the staffing levels should be appropriate, and may include one or more FSS coordinators. If the PHA chooses to contract with an outside organization, the organization's staffing levels must likewise be appropriate to establish and administer the FSS program, and the organization's responsibilities would include managing the FSS account in accordance with federal regulations. PHA Policy The PHA will employ appropriate staff, including one or more FSS coordinators or program coordinators to administer its FSS program. Copyright 2014 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 3-2 Model FSS Action Plan 911114 3 -LC. ADMINISTRATIVE FEES AND COSTS In the past, the ways in which administrative fees and costs were funded were different for public housing and housing choice voucher FSS programs, and the use of such funding was restricted to the applicable program. In the Consolidated Appropriations Act of 2014, however, funding streams for the PH FSS and HCV FSS programs were combined, and all FSS funding is now awarded through one NOFA. Use of this funding is no longer restricted to the applicable program—funding now may be used to serve both PH and HCV FSS participants. Funding will be awarded through a Grant Agreement and disbursed through HUD's Line of Credit Control System (LOCCS), similar to previous PH FSS awards; instead of an amendment to the PHA's Annual Contributions Contract (ACC), which was previously used for HCV awards. PH FSS and HCV FSS funds awarded in prior years are still restricted to the applicable program, Rental Assistance Demonstration (RAD) programs excepted. Funding differences regarding previous years' funding is specified below. Public Housing FSS Program For public housing FSS programs, the performance funding system (PFS), provided under section 9(a) of the 1937 Act provides for the reasonable and eligible administrative costs that the PHA incurs in carrying out the program only when funds have been appropriated. However, a PHA may use other resources for this purpose [24 CFR 984.302(a)]. In other words, the PHA may fund reasonable and eligible administrative costs in the FSS program from the Operating Fund. However, these expenses will only be reimbursed in the operating subsidy when a current appropriations act allows it. In addition, the PHA may fund reasonable and eligible administrative costs from the Capital Fund. Administrative staffing costs may also be funded through HUD or other grant or foundation sources. This includes FSS Coordinator grants when available. Housing Choice Voucher FSS Program In the housing choice voucher program, administrative fees are paid to PHAs for HUD -approved costs associated with the operation of an FSS program. These administrative fees are established by Congress and subject to appropriations [24 CFR 984.302(b)]. In addition, administrative fees for HUD -approved costs not specifically related to the operation of the FSS program may be used to cover these costs associated with the administration of FSS [see Notice PIH 93-24 E-7 and E-8]. C Copyright 2014 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 3-3 Model FSS Action Plan 9/1.14 3 -LD. SUPPORTIVE SERVICES FEES AND COSTS As with administrative fees and costs, funding for supportive services fees and costs are now combined under one funding stream. Supportive services fees and costs include childcare expenses, transportation funds, and the costs of training, work equipment, or GED classes, among others. As with administrative fees and costs, funding will be awarded through a Grant Agreement and disbursed through HUD's Line of Credit Control System (LOCCS), similar to previous PH FSS awards; instead of an amendment to the PHA's Annual Contributions Contract (ACC), which was previously used for HCV awards. Remember, however, that funds awarded in prior years are still restricted to the applicable program. Information for funds under previous years' awards follows. Public Housing Supportive Services In public housing, the PHA may fund reasonable and eligible FSS supportive service costs in the FSS program from either the Operating Fund or the Capital Fund. However, in the Operating Fund, the costs of FSS supportive services are only reimbursed through the operating subsidy when appropriations allow it. In addition to the Operating Fund and Capital Fund, public housing supportive services can also be funded through HUD grants, other than FSS coordinator grants, when available. Housing Choice Voucher Supportive Services In the housing choice voucher program, the PHA may fund reasonable and eligible FSS supportive service costs in the FSS program from unrestricted net assets [see Notice PIH 93-24, E-3]. In addition, the PHA may seek additional funds from HUD through submitting grant applications, or seek grants from other sources when available. 3-I.E. ON-SITE FACILITIES Each PHA may, subject to the approval of HUD, make available and utilize common areas or unoccupied dwelling units in public housing projects to provide supportive services under an FSS program. This includes using such areas for participants in a housing choice voucher FSS program. PHA Policy The PHA does not operate a public housing program and does not have unoccupied dwelling units in public housing projects to provide supportive services. •.' Copyright 2014 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 3-4 Model FSS Action Plan 9f1114 PART II: PROGRAM COORDINATING COMMITTEE 3-II.A. OVERVIEW As another integral part of FSS program administration, each participating PHA must establish a program coordinating committee (PCC) whose functions will be to assist the PHA in securing commitments of public and private resources for the operation of the FSS program within the PHA's jurisdiction, including assistance in developing the action plan and in implementing the program [24 CFR 984.202(a)]. The PCC must consist of certain members, which are dependent upon whether the PHA is operating a public housing or housing choice voucher program. In addition to these required members, the PCC may also include additional members recommended by regulation. 3-II.B. PROGRAM COORDINATING COMMITTEE MEMBERSHIP Required PCC Membership [24 CFR 984.202(b)(1)] For a public housing FSS program, the PCC members required consist of representatives of the PHA and public housing residents. The public housing resident representatives on the PCC will be solicited from one or more of the following groups: • An area -wide or city-wide resident council • If the PHA will be transferring FSS participants to vacant units in a specific public housing development, the resident council or resident management corporation of the public housing development where the public housing FSS program is to be carried out • Any other public housing resident group that the PHA believes is interested in the FSS program and would contribute to the development and implementation of the FSS program For a housing choice voucher FSS program, the PCC membership must consist of representatives of the PHA and participants of the HCV program or HUD's public or Indian housing programs. PHA Policy The PHAs representative to the program coordinating committee will be the FSS coordinator. ® Copyright 2014 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 3-5 Model FSS Action Plan 9,1 14 Recommended PCC Membership [24 CFR 984.202(b)(2)] Membership on the PCC also may include representatives of the unit of general local government served by the PHA, local agencies (if any) responsible for carrying out employment training programs or programs funded under the Workforce Investment Act, and other organizations, such as other state, local, or tribal welfare and employment agencies, public and private education or training institutions, child care providers, nonprofit service providers, private business, and any other public and private service providers with resources to assist the FSS program. PHA Policy The PHA's FSS program coordinating committee membership will include leadership from the following organizations: American Job Center Hawaii Workforce Development Division Hawaii Community College Hawaiian Community Assets Hawaii Island Community Development Corp. Goodwill Hawaii, LLC 3-II.C. ALTERNATIVE PCC COMMITTEE [24 CFR 984.202(c)] It is also possible for the PHA, in consultation with the chief executive officer of the unit of general Iocal government served by the PHA, to use an existing entity as the PCC, as long as the membership of the existing entity consists or will consist of the individuals required by regulation (See section 3-II.B. above). PHA Policy The PHA will not utilize an existing entity as its program coordinating committee. Copyright 2014 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 3-6 Model FSS Action Plan 9;1;14 Chapter 4 SELECTING AND SERVING FSS FAMILIES INTRODUCTION FSS regulations require that the Public Housing Agency (PHA) include in its action plan a statement indicating how it will select families for participation in the FSS program. This includes outreach, waiting list management, and other selection procedures. When followed, the PHA's selection procedures ensure that families will be selected without regard to race, color, religion, sex, handicap, familial status, or national origin. Once selected for participation in the FSS program, families are to be provided various activities and supportive services so that they may obtain the education, employment, and business and social skills necessary to achieve self-sufficiency. A description of such activities and supportive services is also a requirement of the FSS action plan. This chapter contains three parts: Part I: Incentives, Outreach, and Assurance of Noninterference: This part describes the incentives the PHA will offer and the outreach efforts the PHA will use in order to encourage participation and recruit eligible families for the FSS program. It also contains the required assurance of noninterference with the rights of nonparticipating families. Part II: Family Selection: This part covers whether the PHA will use preferences for family selection and which preferences the PHA will employ if they choose to do so. In addition, this part describes the selection factors the PHA will use in screening families for participation in the FSS program. Part III: Activities and Support Services: This part lists the activities and supportive services to be provided to families through both public and private resources, describes the method the PHA will use to identify family support needs, and covers the required certification of coordination. J. Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. 4-1 Model FSS Action Plan 11'1.1 I Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. 4-2 Model FSS Action Plan 12/1:11 PART I. INCENTIVES, OUTREACH, AND ASSURANCE OF NONINTERFERENCE 4-I.A. OVERVIEW The FSS program offers incentives such as the FSS escrow account, case management, and other supportive services that not only encourage participation, but also help families achieve self- sufficiency. In addition to encouraging program participation through such incentives, PHAs also conduct outreach to recruit FSS participants from among eligible families. As part of this process, families need to know that their choice as to whether to participate in the FSS program will not affect their admission to the public housing or housing choice voucher programs, nor will it affect their right to occupancy. This part describes the PHA's policies regarding these issues, all of which are required aspects of the FSS action plan. 4-I.B. INCENTIVES FOR PARTICIPATION [24 984.201(d)(5)] By regulation, the FSS action plan must include a PHA's incentives plan— -a description of the incentives that the PHA intends to offer eligible families to encourage their participation in the FSS program. The incentives plan provides for the establishment of the FSS escrow account and any other incentives designed by the PHA PHA Policy The PHA will offer the following services to its FSS participants as incentives to participate in FSS: Incentive Provided By Description FSS escrow account FSS program The FSS program will match and deposit monthly into an escrow savings account any increases in family earned income resulting in increases in 30 percent of the family's adjusted monthly income. Families are eligible to receive the accumulated savings when they graduate from the program. Case management FSS coordinator FSS families will receive support, encouragement and guidance toward achieving their goals toward self- sufficiency. Information on and referrals to services FSS coordinator FSS families will receive information on and referrals to local supportive services that are invested in the success of the FSS program. These services include but are not limited to employment services, training, education, counseling, financial literacy, credit counseling, home buyer education, health care and child care. © Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. 4-3 Model FSS Action Plan 12 1/11 4-I.C. OUTREACH EFFORTS [24 CFR 984.201(d)(6)(i)(ii)] In addition to offering incentives for FSS participation, PHAs also conduct outreach in order to recruit more FSS participants from eligible families. The FSS action plan must include a description of these efforts to recruit FSS participants, including notification and outreach, the actions the PHA will take to assure that both minority and nonminority groups are informed about the FSS program, and how the PHA will make this information known. PHA Policy The PHA will notify eligible families about the FSS program using the following outreach locations or activities and methods. These points of contact and methods have been selected to ensure that both minority and nonminority groups are informed about the FSS program. Location/Activity Staff/Partner Method Language New Admission PHA Staff Invitational letter with flyer English PHA Informational Meetings PHA Staff Specialist Power Point Presentation English Annual Re- certifications PHA Staff Specialist Flyer attached to appointment letters PHA Staff referrals English Interim Re- certifications Specialists Flyer attached to rent adjustment notices resulting from zero income families English Lobby/Waiting Room PHA Staff Receptionist Flyer English Inspections PHA Staff Flyer attached to inspection appointment letters English American Job Center Resource Center Flyer English Website PHA Staff Description and flyer English Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for intcmal use. 4-4 Model FSS Action Plan 12:1+11 4 -LD. ASSURANCE OF NONINTERFERENCE WITH THE RIGHTS OF NONPARTICIPATING FAMILIES [24 CFR 984.201(d)(10)J A family's housing assistance or admission into assisted housing should never depend on whether they choose to participate in the FSS program, and PHAs need to make this known as part of the recruitment process. For this reason, the PHA's action plan must include an assurance that a family's decision to not participate in the FSS program will not affect the family's admission to the public housing or housing choice voucher programs, nor will it affect the family's right to occupancy in accordance with the lease. PHA Policy Participation in the FSS program is strictly voluntary. Housing choice voucher program participants will be notified in all literature and media presentations related to the FSS program that should they decide not to participate in the FSS program it will not affect their HCV housing assistance. This material will also specify that the family will retain the right to occupancy according to their lease and family obligations contract. e Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. 4_5 Model FSS Action Plan 12/1111 THIS PAGE IS INTENTIONALLY LEFT BLANK " Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. 4-6 Model FSS Action Plan 1211/11 PART II. FAMILY SELECTION 4-II.A. OVERIVEW The FSS action plan is required to contain a statement indicating the procedures for selecting families for FSS program participation, including a description of how the PHA will do so without regard to race, color, religion, sex, handicap, familial status, or national origin. This part describes these procedures, taking into account whether the PHA will use preferences for family selection and which preferences the PHA will employ if they choose to do so, in addition to defining the factors the PHA will use in screening families for program participation. 4-II.B. FSS SELECTION PREFERENCES As part of the process for selecting families for participation in the FSS program, the PHA may choose whether to employ the use of preferences. In particular, if the PHA so chooses, it has the option of giving a selection preference for up to 50 percent of its public housing FSS slots and 50 percent of its HCV program FSS slots, respectively, to eligible families who have one or more family members currently enrolled in an FSS -related service program or who are on the waiting list for such a program. Such a preference may be further limited to participants in and applicants for one or more specific eligible FSS -related service programs. Should the PHA choose to adopt such a preference, it would need to include the following information in its action plan: • The percentage of FSS slots, not to exceed 50 percent of the total number of FSS slots for each of its FSS programs, for which it will give a selection preference • The FSS related service programs to which it will give a selection preference to the programs' participants and applicants • The method of outreach to and selection of families with one or more members participating in the identified programs [24 CFR 984.203(a)] A PHA may wish to adopt additional selection preferences as well [Notice PIH 93-24]. PHA Policy The PHA will not adopt the use of preferences when selecting families for participation in the FSS program. i0 Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. 4-7 Model FSS Action Plan 12.111 Even with up to 50 percent of the total number of FSS slots filled via selection preferences, and the possibility of other slots being filled by means of additional preferences, open slots will remain. Regardless of whether the PHA adopts selection preferences, those FSS slots for which the PHA chooses not to exercise the selection preference must be filled with eligible families in accordance with an objective selection system such as a lottery, the length of time living in subsidized housing, or the date the family expressed an interest in participating in the FSS program. This system must be described in the action plan [24 CFR 984.203(b)}. PHA Policy The PHA will objectively select families to participate in the FSS program by using the date and time a family's FSS application is received. Families will receive an FSS application after attending an informational meeting to team about the program. There is a maximum of seventy-five (75) slots available. If there are available slots families will be enrolled. If there are no available slots applications will be placed on an FSS waitlist and families will be offered on a first-come first-served basis when FSS slots become available. Once a family is selected, they must complete a needs -based assessment. The family must also sign program authorization forms, sign receipt of the OHCD FSS handbook, and sign the program certification of understanding and the contract of participation which includes an individual training service plan. The PHA chooses not to exercise any selection preference. 4-II.C. SELECTION FACTORS Many factors contribute to whether a PHA may choose to select a family for participation in the FSS program. These selection factors can help the PHA screen families for admission, and ultimately contribute to the PHA's decision to either allow or deny a family's admission into the FSS program. Motivation Selection Factors 124 CFR 984.203(c)(1)] A PHA may screen families for interest and motivation to participate in the FSS program provided that the factors utilized by the PHA are those which solely measure the family's interest and motivation to participate in the FSS program. For this reason, PHAs must only apply motivational screening factors that are permissible under the regulations. Permissible Motivation Selection Factors © Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. 4-8 Model FSS Action Plan 12/1.11 Permitted motivational factors include requiring attendance at FSS orientation sessions or pre- selection interviews, and assigning certain tasks indicating the family's willingness to undertake the obligations that may be imposed by the FSS contract of participation. However, any tasks assigned should be readily accomplishable by the family based on the family members' educational level or disabilities, if any. Reasonable accommodations must be made for individuals with mobility, manual, sensory, speech impairments, mental, or developmental disabilities [24 CFR 984.203(c)(2)]. PHA Policy The PHA will not screen families for interest and motivation to participate in the FSS program. Prohibited Motivation Selection Factors Prohibited motivational screening factors include the family's educational level, educational or standardized motivational test results, previous job history or job performance, credit rating, marital status, number of children, or other factors, such as sensory or manual skills, and any factors which may result in discriminatory practices or treatment toward individuals with disabilities or minority or nonminority groups [24 CFR 984.203(C)(3)]. Other Selection Factors In addition to motivational screening, the PHA may also wish to screen families for other factors. PHA Debt Selection Factor The PHA may deny FSS participation to a family if the family owes the PHA, or another PHA, money in connection with HCV or public housing assistance [Notice PIH 93-24, B-18]. PHA Policy The PHA will deny FSS participation to a family if the family owes the PHA, or another PHA, money in connection with HCV or public housing assistance. Families that owe money to a PHA who have entered into a repayment agreement and are current on that repayment agreement will not be denied FSS participation. Unavailable Support Services Selection Factor If the PHA determines, after consulting with the family, that a missing service is essential to the family's needs, the PHA may skip that family (and other similar families) and offer the FSS slot to the next family for which there are available services [Notice PIH 93-24, B-8]. PHA Policy The PHA will allow the family to decide if they want their application to be skipped if a missing service is essential to the family's needs. Previous Participation Selection Factor ry' Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. 4-9 Model FSS Action Plan 1211.11 A PHA may refuse to select a family for participation in the FSS program a second time if that family previously participated unsuccessfully (i.e., the family participated, did not meet its FSS obligations, and was terminated from the FSS program) [Notice PIH 93-24, B-14]. PHA Policy The PHA will not select a family for participation in the FSS program during the 12 - month period after the family's contract of participation was terminated. A family must wait one year to apply for participation in the program a second time if they did not previously graduate. A family may not participate a second time or re -enroll in the FSS program if they had already graduated from an FSS program. iv Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. 4-10 Model FSS Action Plan 12:1 `I 1 PART III. ACTIVITIES AND SUPPORT SERVICES 4-III.A. OVERVIEW Once families are admitted to the FSS program, the PHA becomes responsible for making sure these families are adequately served. The purpose of the family self-sufficiency (FSS) program is to promote the development of local strategies to coordinate the use of public housing assistance and assistance under the housing choice voucher programs with public and private resources, to enable families eligible to receive assistance under these programs to achieve economic independence and self-sufficiency. As such, upon selection, families are matched with the appropriate activities and supportive services so that they may obtain the education, employment, and business and social skills necessary to achieve self-sufficiency. This is a vital element of the FSS program. 4-1II.B. METHOD OF IDENTIFYING FAMILY SUPPORT NEEDS [24 CFR 984.201(d)(8)] Before a PHA can determine the services and activities it will provide to FSS families, it must identify the services and activities appropriate to each family. The action plan must contain a description of how the program will identify the needs of FSS families and deliver the services and activities according to these needs. PHA Policy Supportive services needs will be identified by completion of an informal need's assessment with the FSS coordinator or case manager before completion of the initial individual training and services plan, receipt and acknowledgment of the OHCD FSS handbook and signing of the certification of understanding and contract of participation. After enrollment in the PHA's FSS program, a formal needs assessment, including vocational counseling, educational counseling, and employment planning, may be conducted by the following partners on the PCC: American Job Center Hawaii Workforce Development Division Hawaiian Community Assets Hawaii Community College Assessments may also be completed by other support services as needed. These results are used to modify the ITSP, if requested by the family. The family must also sign an authorization of release of information from these partners and other service providers. c Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. 4-11 Model FSS Action Plan 111/11 4-IILC. FSS ACTIVITIES AND SUPPORT SERVICES DESCRIPTION 124 CFR 984.201(d)(7)1 As part of the required contents of the action plan, PHAs must both describe the activities and supportive services to be provided by public and private resources to FSS families, and identify the public and private resources that are expected to provide the supportive services. Of course, this task assumes that the PHA has first identified the needed activities and supportive services. PHA Policy The PHA's FSS program, through its partners on the program coordinating committee, will provide the following activities and support services to FSS families: Support Service General Support Service Specific Source/Partner Assessment Vocational Assessment / Planning Educational Assessment / Planning Drug/Alcohol Assessment Drug/Alcohol Planning American Job Center Hawaii Workforce Development Division Waipahu Community School for Adults Hawaii Community College Hawaiian Community Assets BISAC Education English as a Second Language GED Post -secondary Waipahu Community School for Adults Hawaii Community College Waipahu Community School for Adults Hawaii Community College American Job Center Hawaii WIOA Workforce Development Division Training Skills Training On -the -Job Training Functional Context Training Job Search Assistance Resume Preparation Interviewing Skills Dress for Success Workplace Skills Job Development Job Placement American Job Center of Hawaii Workforce Development Division Hawaiian Community Assets Goodwill Hawaii Transportation Bus Shared Ride Taxi Hawaii Island Hele-On Bus © Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. 4-12 Model FSS Action Plan 12/1/11 Support Service General Support Service Specific Source/Partner Health Care AIcohol and Drug Prevention Alcohol and Drug Treatment Department of Human Services Department of Health Bay Clinic Hilo Urgent Care Hilo Medical Center Micro and Small Business Development Training Planning Technical Assistance Mentoring Training Planning Debt Resolution Hawaii Small Business Development Center Office of Housing & Community Development Hawaiian Community Assets Hawaii Island Community Development Corporation United States Department of Agriculture — Rural Development Hawaii HomeownershipCenter Hawaiian Community Assets Homeownership Individual Development Accounts Match Savings Accounts Distribution of IDA Funds Child Care Infant Care Toddler Care Preschool Care Afterschool Care Homework Assistance Department of Human Services PATCH Crisis Services Crisis Assessment Crisis Intervention Crisis Management Crisis Resolution Department of Human Services Care Hawaii Child/Adult Protective Services Needs Assessment Case Planning Information Referral Crisis Management Department of Human Services Legal Services Representation Document Review Counsel or Advice Legal Aid Society of Hawaii 'a' Copyright 2011 by Nan McKay & Associates ['nlimited copies may be made for internal use. 4-13 Model FSS Action Plan 1211111 upport Service General Debt Resolution Support Service Specific Needs Assessment Case Nanning Advocacy Negotiation Source/Partner Hawaiian Community Assets 4-IILD. CERTIFICATION OF COORDINATION 124 CFR 984.201(d)(12)j The FSS action plan is required to contain a certification that the development of the activities and services under the FSS program has been coordinated with the JOBS program (now Welfare to Work under TANF), the programs provided under the JTPA (now Workforce Investment Act programs), and any other relevant employment, child care, transportation, training, and education programs in the applicable area. The implementation of the FSS program's activities and services must continue to be coordinated as such in order to avoid duplication of activities and services. PHA Policy The PHA certifies that its FSS program has developed its services and activities in coordination with the Workforce Investment Act (formerly JTPA), Workforce Investment Board and One Stop Centers, Welfare to Work (formerly JOBS program), and any other relevant employment, child care, transportation, training, and education programs in the applicable area. The implementation of these activities and services will continue to be coordinated in this manner in order to avoid duplication of activities and services. t Copyright 2011 by Nan McKay & Associates t;nlimited copies may be made for internal use. 4-1 4 Model FSS Action Plan 12/1,11 Chapter 5 CONTRACT OF PARTICIPATION INTRODUCTION Each family that is selected to participate in an FSS program must enter into a contract of participation with the Public Housing Agency (PHA). This contract, which is signed by the head of the FSS family, sets forth the principal terms and conditions governing participation in the FSS program, including the rights and responsibilities of the FSS family and of the PHA, the services to be provided to the head of the FSS family and each adult member of the family who elects to participate in the program, and the activities to be completed by them. The contract also incorporates the individual training and services plan [24 CFR 984.3031. This chapter contains two parts: Part I: Overview and Family Obligations: This part provides an overview of the form and content of the contract of participation and describes what the contract requires of FSS families. Part II: Contract Specifications: This part explains the specifications of the contract, including terms and conditions, contract modification, contract terminations, and grievance procedures. PART I: OVERVIEW AND FAMILY OBLIGATIONS 5-I.A. OVERVIEW The purpose of the FSS contract of participation is to set forth the principal terms and conditions governing participation in the FSS program, including the incorporation the individual training and services plan (ITSP) as part of the contract's required contents. The ITSP is meant to establish goals for an FSS family to meet along the family's way to completing the contract and becoming self-sufficient. In addition to the goals specified in the ITSP, the contract also lists the responsibilities of the family and the PHA. This part covers the ITSP as part of the required contents of the contract of participation, and the family's obligations under the contract. Copyright 2017 by Nan McKay & Associates t:nlimited copies may be made for internal use. Page 5-1 FSS Action Plan 6.1:'17 5 -LB. CONTENTS OF THE CONTRACT OF PARTICIPATION Individual Training and Services Plan As part of the required contents of the FSS contract of participation (COP), the individual training and services plan (ITSP) establishes specific interim and final goals by which the PHA and the family measure the family's progress toward fulfilling its obligations under the contract of participation and becoming self-sufficient. Interim and final goals will differ depending on the family's individual needs. Further, regulations require the establishment of an interim goal regarding independence from welfare assistance. Interim Goals For each participating FSS family that receives welfare assistance, the PHA must establish as an interim goal that the family become independent from welfare assistance and remain independent from welfare assistance for at least one year before the expiration of the term of the contract of participation, including any extension thereof [24 CFR 984.303(b)(2)]. At its discretion, the PHA may also elect to suggest this as an interim goal in the ITSP regardless of whether a family is receiving welfare assistance at the time the COP is developed. PHA Policy The PHA will suggest to each family participating in the FSS program, regardless of whether the family is receiving welfare assistance at the time the contract of participation is being developed, that the family include an interim goal on its individual training and services plan for the family to become independent from welfare assistance and remain welfare -free for at least one year before the expiration of the term of the contract of participation. Individual Training & Service Plans for Other than FSS Head An individual training and services plan is only required for the head of the FSS family. This means that it is the PHA's decision, after consulting with the family, whether to create an ITSP and provide supportive services to other family members aged 18 or over if they want to participate in the FSS program and supportive services are available [Notice PIH 93-24, G-16]. PHA Policy The PHA will permit additional family members to have an ITSP. bh Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 5-2 FSS Action Plan 6:`1'17 5-I.C. FAMILY OBLIGATIONS Compliance with Lease Terms One of the obligations of the FSS family according to the contract of participation is to comply with the terms and conditions of the public housing lease or housing choice voucher program assisted lease [24 CFR 984.303(b)(3)]. Inability to comply with the lease represents an inability to comply with the contract, therefore regulations regarding noncompliance with the FSS contract apply [see 24 CFR 984.303(b)(5)]. It is up to the PHA to determine the plan of action for FSS families found in noncompliance with the lease and how the PHA will precisely define the term comply with the lease. PHA Policy Comply with the lease means the FSS family has not been evicted for repeated or serious violations of the lease; or if they have been evicted for serious or repeated violations of the lease, the family has prevailed in either the grievance hearing or the informal hearing process. The PHA's FSS program will terminate the FSS contract of participation for failure to comply with the terms of the lease. Employment Obligation [24 CFR 984.303 (b)(4)] Another obligation set forth by the contract of participation is for the head of the FSS family to seek and maintain suitable employment during the term of the contract and any extension. Although other members of the FSS family may seek and maintain employment during the term of the contract, it is only a requirement for the head of the FSS family. The obligation for the head of the FSS family to seek employment is defined in the regulatory language as meaning that the head of the FSS family has applied for employment, attended job interviews, and has otherwise followed through on employment opportunities. However, this definition still leaves room for policy decisions on the part of the PHA because it does not define the level of activity involved in "seeking." There is no regulatory definition of maintain employment. For this reason, it is up to the PHA to define the term. In addition, there is no minimum period of time that an FSS head of household needs to be employed in order to meet its contract of participation requirements [Notice PIH 93-24, G-9]. According to regulation, the PHA makes a determination of suitable employment based on the skills, education, and job training of the FSS head of household, and based on the available job opportunities within the jurisdiction served by the PHA [24 CFR 984.303(b)(4)(iii)]. This means that the PHA has the ultimate responsibility for making the decision regarding the suitability of employment. However, this decision must be made in conjunction with the head of the FSS family [Notice PIH 93-24, G-3]. PHA Policy For purposes of the PHA's FSS program, seek employment means the head of household has applied for employment, attended job interviews, and otherwise followed through on Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 5-3 FSS Action Plan 6:117 employment opportunities as outlined in the individual training and services plan of his or her contract of participation. Maintain employment means that the FSS head of household will complete all of the obligations outlined in the individual training and services plan in his or her contract of participation (COP) and be employed full-time working at least 32 hours per week on the last effective day of the COP; or, be employed part-time and enrolled, and participating as agreed, in a full-time education or training program on the last effective day of the COP. The PHA will require verification of this employment or enrollment. Suitable employment is any full-time employment that is obtained by the FSS head of household working at least 32 hours per week earning more than Hawaii's minimum wage standard unless there is potential for advancement or part-time employment and enrolled in full-time education or training program. Employment must be with an established legitimate business where the participant is receiving a regular paycheck from which taxes and other required deductions are withheld. Employment must be considered a lawful activity. Suitable Full -Time Self -Employment is when a participant's net annual income (after business expense deductions) equals the suitable employment definition above (earning more than Hawaii's minimum wage multiplied by 32 hours per week). Contracted or commission employment will be considered if it meets the suitable employment definition above, is verifiable, and is being declared for tax purposes. In cases where participants are both self-employed and employed through an employer, and the self- employment income does not exceed the suitable employment definition above, the combined total gross earnings from employment and net self-employment income must be more than the suitable definition above (more than minimum wage multiplied by 32 hours per week). Self-employment must be verifiable through signed Federal income tax returns (Schedule C). Requests for accommodations for a person with disability to the employment standards must be supported by a written verification from the individual's medical provider stating the amount of hours that the individual is able to work. '&" Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 5-4 FSS Action Plan 6/1117 5-I.D. CONSEQUENCES OF NONCOMPLIANCE WITH THE CONTRACT Consequences apply for families who do not meet the terms and conditions of the contract. The regulations require that the contract of participation specify that if the FSS family fails to comply, without good cause, with the terms and conditions of the contract (including compliance with the public housing lease or the HCV -assisted lease), the PHA may: • Withhold supportive services • Terminate the family's participation in the FSS program Per the alternative requirements listed in the Federal Register notice dated December 29, 2014, PHAs are no longer permitted to terminate HCV assistance to a family due to the family's failure to meet its obligations under the contract of participation [FR Notice 12129114]. PHA Policy The contract of participation (COP) will be terminated before the expiration of the contract term if the participant fails to meet, without "good cause," their obligations as outlined in the COP. If the participant fails to meet its obligations outlined in the COP, the FSS coordinator, or their designee, will first meet with the family to reassess the need for supportive services or a change in the individual training and services plan (ITSP). Then, if a reassessment of supportive services or a change in the ITSP is not successful in bringing the family in compliance, the FSS coordinator will withhold supportive services for no more than 90 days until the participant meets their obligations outlined in the COP. Finally, if neither of these alternatives is successful, the FSS coordinator will terminate the COP for failure to complete the tasks, interim goals, or final goals of the ITSP in a timely manner, and thus failure to complete the obligations outlined in the COP. The FSS coordinator will make an exception to the actions in terminating the COP if the participant can demonstrate "good cause" for the failure to meet its obligations as outlined in the COP. For purposes of the PHA FSS program, good cause includes: Family circumstances Death in the family Serious illness Medical emergency Mandatory court appearances Involuntary loss of employment Loss of head of household through death, incarceration, or removal from lease Change in the ITSP improving progress toward economic self-sufficiency Community circumstances Significant reduction in workforce (over 20 percent reduction in employment field) Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 5-5 FSS Action Plan 6/11 7 Significant interruption in service delivery (over 3 months interruption) Provider noncompliance with regulation Provider unable/unwilling to provide service Provider offering inferior service Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 5-6 FSS Action Plan 6/1:17 PART II. CONTRACT SPECIFICATIONS 5-II.A. OVERIVEW In addition to making clear the family's obligations under the program, the contract of participation contains specific terms and conditions, including those governing contract modifications, terminations, and grievance procedures. This part describes those specifications and associated policy. 5-II.B. CONTRACT TERM [24 CFR 984.303(c)] The contract term is five years. This means that the family has no more than five years from the effective date of the contract of participation (COP) to fulfill their obligations as specified in the contract. This five year term requirement will be specified in the COP. Contract Extension 124 CFR 984.303(d)] While the term set forth in the contract of participation is for five years, contract extensions are possible. According to regulation, PHAs will for "good cause" extend the term of the contract for a period not to exceed two years for any FSS family that requests an extension of the contract in writing. The family's written request for an extension must include a description of the need for the extension. Good cause means circumstances beyond the control of the FSS family, as determined by the PHA, such as a serious illness or involuntary loss of employment (further defined by PHA policy in Section 5 -LD.). Extension of the contract of participation will entitle the FSS family to continue to have amounts credited to the family's FSS account. PHA Policy The family's written request for an extension must include description of the need for the extension as well as an explanation of why the goals were not completed, what goals still need to be completed and the time frame in which the goals will be completed. Participants will be notified in writing of decision within fourteen (14) business days and may request an informal review if they disagree with the decision (see 5-1I-1 Grievance Procedures, page 5-13). The family will be required to continue abiding by the contract of participation (COP) and individual training and services plan (ITSP), as well as keep in regular contact with a FSS coordinator during the extension. If granted, the COP and ITSP will be amended to reflect the extension. Failure to comply with agreed upon extension conditions will result in contract termination and forfeiture of the escrow balance. Copyright 2017 by Nan McKay & Associates Unlimited copies may be made Tor internal use. Page 5-7 FSS Action Plan 6/1i17 5-II.C. MODIFICATION OF THE CONTRACT The contract of participation (COP) does have the ability to be modified, as long as the PHA and the FSS family mutually agree to modify it. This includes modifications in writing with respect to the individual training and services plans (ITSPs), the contract term (See Section 5-II.B. above), and designation of the head of the family [24 CFR 984.303(f)]. In addition, the PHA may also delete the line in the COP under "Corrective Actions to Meet Family Responsibilities" stating that if the family is participating in the HCV program, the PHA may terminate HCV assistance when allowed by HUD requirements. Mutual agreement is not needed for this modification [Notice PIH 95-5]. Termination of HCV assistance is covered in further detail in Section 5-II.G.The conditions under which the PHA will modify the contract are set forth in the policy below. PHA Policy In the PHA's FSS program, the COP will be modified by mutual agreement between the PHA and the head of household: When modifications to the ITSP improve the participant's ability to complete their obligations in the COP or progress toward economic self-sufficiency. The ITSP may be modified when family needs and goals towards economic self- sufficiency change over time or to add new goals. Modifications to the ITSP will not be allowed during the last six (6) months of participation. When the designated head of the FSS family ceases to reside with other family members in the assisted unit, and the remaining family members, after consultation with the public housing or HCV program representative, designate another family member to be the head of the FSS family assuming responsibility of the COP and receive escrow funds. When a relocating family is entering the FSS program of a receiving PHA and the start date of the COP must be changed to reflect the date the new COP is signed with the receiving PHA. The end date of the new COP must remain the same. The PHA will also remove the line under "Corrective Actions to Meet Family Responsibilities" stating that if the family is participating in the HCV program, the PHA may terminate the assistance when allowed by HUD requirements. Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 5-8 FSS Action Plan 611/17 5-II.D. COMPLETION OF THE CONTRACT By regulation, the contract of participation is considered to be completed, and a family's participation in the FSS program is considered to be concluded when one of the following occurs [24 CFR 984.303(g)]: • The FSS family has fulfilled all of its obligations under the contract of participation on or before the expiration of the contract term, including any extension thereof. • 30 percent of the monthly adjusted income of the FSS family equals or exceeds the published existing housing fair market rent for the size of the unit for which the FSS family qualifies based on the PHA's occupancy standards. The contract of participation will be considered completed and the family's participation in the FSS program concluded on this basis even though the contract term, including any extension thereof, has not expired, and the family members who have individual training and services plans have not completed all the activities set forth in their plans. Policies on verifying completion of the contract of participation can be found in Section 6-I.C. of this action plan. 5-II.E. TRANSITIONAL SUPPORTIVE SERVICE ASSISTANCE Even after a family has completed the contract of participation, a PHA may continue to offer appropriate FSS supportive services to a former FSS family whose head of family is employed. If the family still resides in public housing, or HCV -assisted housing, these supportive services would be offered for becoming self-sufficient. If the family no longer resides in public housing, HCV -assisted housing, or other assisted housing, these supportive services would be offered for remaining self-sufficient [24 CFR 984.303(j)]. PHA Policy The PHA will continue to offer supportive services to a former FSS family who has completed its contract of participation, and whose head of family is employed. 4' Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 5-9 FSS Action Plan 6/1217 5-ILF. TERMINATION OF THE CONTRACT The contract of participation may be terminated before the expiration of the contract term and any extension of the contract by the following [24 CFR 984.303(h)]: • Mutual consent of the parties • Failure of the FSS family to meet its obligations under the contract of participation without good cause, including in an HCV FSS program the failure to comply with the contract requirements because the family has moved outside the jurisdiction of the PHA • The family's withdrawal from the FSS program • Such other act as is deemed inconsistent with the purpose of the FSS program • Operation of law PHA Policy The COP will be terminated before the expiration of the contract term, and any extension thereof, for any of the following reasons: Mutual consent of the parties Failure of the FSS family to meet its obligations under the contract of participation and complete the goals and activities of the ITSP without good cause In an HCV FSS program, failure to comply with the contract requirements because the family has moved outside the jurisdiction of the PHA without continued assistance under portability Family's withdrawal from the FSS program Such other act as is deemed inconsistent with the purpose of the FSS program Operation of law If the FSS family faces termination due to failing to meet, without good cause, its obligations under the COP, the PHA will follow the relevant policy specified in Section 5-I.D. of this action plan. Good cause for the purposes of the FSS program is also defined in Section 5-I.D. In addition, the contract of participation is automatically terminated if the family's HCV assistance is terminated in accordance with HUD requirements [24 CFR 984.303(h)]. ® Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 5-10 FSS Action Plan 6/1/17 5-II.G. OPTION TO WITHHOLD OR TERMINATE SUPPORTIVE SERVICE AND HOUSING ASSISTANCE [24 CFR 984.303(b)(5)(i)] As touched upon in Section 5-I.D. of this action plan, the PHA has the option to terminate or withhold supportive services and the FSS family's participation in the FSS program if the PHA determines that the FSS family has failed to comply without good cause with the requirements of the contract of participation. Per the alternative requirements listed in the Federal Register notice dated December 29, 2014, however, PHAs are no longer permitted to terminate HCV assistance to a family due to the family's failure to meet its obligations under the contract of participation [FR Notice 12/29/14]. 5-II.H. NULLIFICATION OF CONTRACT FOR UNAVAILABILITY OF SUPPORTIVE SERVICES [24 CFR 984.303(e)] In addition to termination, the contract of participation can also be ended ahead of time as a result of integral supportive services being unavailable. This, however, should only occur as a last resort: • If a social service agency fails to deliver the supportive services pledged under an FSS family member's individual training and services plan (ITSP), the PHA must make a good faith effort to obtain these services from another agency. • If the PHA is unable to obtain the services from another agency, the PHA must reassess the family member's needs and determine whether other available services would achieve the same purpose. • If other available services would not achieve the same purpose, the PHA shall determine whether the unavailable services are integral to the FSS family's advancement or progress toward self-sufficiency. • If the unavailable services are not integral to the FSS family's advancement toward self- sufficiency, the PHA must revise the ITSP, delete these services, and modify the contract of participation to remove any obligation on the part of the FSS family to accept the unavailable services. • If the unavailable services are determined to be integral to the FSS family's advancement toward self-sufficiency (which may be the case if the affected family member is the head of the FSS family), the PHA shall declare the contract of participation null and void. Nullification of the contract of participation on the basis of unavailability of supportive services shall not be grounds for termination of HCV assistance. Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 5-11 FSS Action Plan 6;1;17 5-II.I. GRIEVANCE PROCEDURES When adverse action is taken by the PHA against a family, the PHA is required to provide a grievance hearing in the public housing program, or an informal hearing in the housing choice voucher program [24 CFR 966 subpart B, 24 CFR 982.554]. According to regulatory requirements, the FSS action plan must contain the grievance and hearing procedures available for FSS families against whom the PHA has taken adverse action with regards to FSS [24 CFR 984.201(d)(9)]. PHA Policy The grievance and informal review procedures for the FSS program will be the same as the grievance and hearing procedures adopted for the housing choice voucher programs in the PHA's admissions and continued occupancy policy and administrative plan, respectively (See Rules and Regulations of the Office of Housing and Community Development, pages 16-11 to 16-31). Adverse actions taken within the FSS program include: Denial of admission into the FSS program Denial of request for supportive services Denial of request to change the ITSP Denial of request to change the head of household Denial of request for interim disbursement of the escrow account Denial of request to complete the COP Denial of a request for extension to the FSS COP Denial of request for final distribution of the escrow account or any portion thereof Withholding of support services Termination of the FSS COP Denial of transitional services C^ Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 5-12 FSS Action Plan 6!1{17 Chapter 6 ESCROW ACCOUNT INTRODUCTION The establishment of an escrow account is offered as a financial incentive to families for participation in the FSS program. Generally, under this incentive, the amount of an increase in family rent resulting from an increase in earned income is escrowed. That is, usually a family's rent or share of the rent goes up when the family experiences an increase in earned income. In the FSS program, this is still the case, but the part of the rent representing the increase is deposited into an account as an escrow credit. The funds from this escrow account then become available to FSS families upon successful completion of their contracts of participation. This chapter explains how the FSS escrow account works, including calculating the amount of the escrow credit and disbursing the funds, and also covers the proper way for the Public Housing Agency (PHA) to manage and report on the account. This chapter contains two parts: Part I: The Escrow Account: This part provides an overview of how the escrow account works, including calculating the escrow credit and disbursing the funds upon completion of the contract of participation. Part II: Escrow Fund Accounting and Reporting: This part describes the requirements for managing the escrow account, including both accounting and reporting requirements. PART I. THE ESCROW ACCOUNT 6-I.A. OVERVIEW As an integral incentive to the FSS program, it is very important to have clear-cut policy spelling out how the escrow account works. This includes policy regarding the calculation of the FSS credit amount, the disbursement of FSS account funds, the use of account funds for homeownership, and forfeiture of the FSS escrow account. Copyright 20I I by Nan McKay & Associates Unlimited copies may be made for internal use. Page 6-1 Model FSS Action Plan 12/1.'11 6-I.B. CALCULATING THE FSS CREDIT AMOUNT For FSS families who are very low-income families, the FSS credit is the lesser of 30 percent of current monthly adjusted income less the family rent, or the current family rent less the family rent at the time of the effective date of the contract of participation. The family rent is obtained by disregarding any increases in earned income (as defined in 24 CFR 984.103) from the effective date of the contract of participation. For FSS families who are considered low-income families but not very low-income families, the FSS credit is calculated in the same manner but cannot exceed the amount computed for 50 percent of the median income [24 CFR 984.305(b)(1)]. FSS families who are not low-income families are not entitled to any FSS credit [24 CFR 984.305(b)(2)]. Determination of Family Rent and Total Tenant Payment For purposes of determining the FSS credit, family rent for the public housing program is the total tenant payment as defined in 24 CFR Part 5, subpart F. For the HCV program, family rent is 30 percent of adjusted monthly income [24 CFR 984.305(b)(1)]. Total tenant payment for a family participating in the public housing FSS program is determined in accordance with the regulations set forth in 24 CFR Part 913. Increases in FSS Family Income [24 CFR 984.304] As described in the FSS credit calculations above, any increases in family earned income resulting in increases in family rent become deposited in the escrow account. For this reason, and because of the nature of the FSS account, any increase in the earned income of an FSS family during its participation in an FSS program may not be considered as income or a resource for purposes of eligibility of the FSS family for other benefits, or amount of benefits payable to the FSS family, under any other program administered by HUD, unless the income of the FSS family equals or exceeds 80 percent of the area median income (as determined by HUD, with adjustments for smaller and larger families). Cessation of FSS Credit [24 CFR 984.305(b)(3)] The PHA will not make any additional credits to the FSS family's FSS account when the family has completed the contract of participation, or when the contract of participation is terminated or otherwise nullified. L% Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 6-2 Model FSS Action Plan 12 1.11 6-I.C. DISBURSEMENT OF FSS ACCOUNT FUNDS Disbursement at Completion of Contract [24 CFR 984.305(c)(1)1 When the contract has been completed according to regulation, the amount in an FSS account in excess of any amount the FSS family owes to the PHA will be paid to the head of the FSS family. However, in order to receive the disbursement, the head of the FSS family must submit a certification (as defined in §984.103) to the PHA at the time of contract completion that, to the best of his or her knowledge and belief, no member of the FSS family is a recipient of welfare assistance. Disbursement before Expiration of Contract Term (Interim Disbursement) FSS account funds may also be disbursed before the end of the contract term. If the PHA determines that the FSS family has fulfilled its obligations under the contract of participation before the expiration of the contract term and the head of the FSS family submits a certification that, to the best of his or her knowledge, no member of the FSS family is a recipient of welfare assistance, the amount in the family's FSS account in excess of any amount the family owes to the PHA will be paid to the head of the FSS family [24 984.305(c)(2)(i)]. In addition, the PHA may at its sole option disburse FSS account funds before completion of the contract if the family needs a portion of the funds for purposes consistent with the contract of participation and the PHA determines that the FSS family has fulfilled certain interim goals established in the contract of participation. Such cases could include using the funds to assist the family in meeting expenses related to completion of higher education (e.g., college, graduate school) or job training, or to meet start-up expenses involved in creation of a small business [24 984.305(c)(2)(ii)]. PHA Policy The PHA will disburse a portion of the FSS escrow account funds before completion of the COP (interim disbursement) for completion of higher education (i.e., college, graduate school), job training, work related costs (including purchase and repairing a vehicle used to travel to and from work) or to meet start-up expenses involved in creation of a small business. The PHA will disburse a portion of the FSS escrow account funds before completion of the COP when the family has met all its obligations under the COP to date, including the completion of all ITSP interim goals and tasks to date, and requested funds are needed in order to complete an interim goal or task within the COP and are not ongoing expenses. The head of household must contribute a portion towards the expense. All interim disbursements will be limited to 25% of the amount in the escrow account, at the time of the request. The head of household must submit a budget along with a written request for an interim disbursement 30 days prior to stated use. The written request must include: how the funds will be used; the amount of money requested; the amount of money the family will contribute; verification that goals and activities listed on the ITSP are completed to date; how this will facilitate their movement towards self-sufficiency; alternate funding sources they have tried. r Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 6-3 Model FSS Action Plan 12'1,11 Interim disbursement checks will only be issued to the appropriate entity with an established Vendor File with the County of Hawaii Finance Department. If the entity does not have Vendor File one must be established. Should the family not complete its FSS contract, the family is not required to repay the amount received as an interim disbursement unless the advance payment was made based on fraudulent information. Verification of Family Certification at Disbursement Interim disbursement may only occur after the family has completed certain interim goals and funds are needed in order to complete other interim goals. Final disbursement can only occur after the family has completed the contract of participation and all members are welfare -free as defined by regulation. Because of this, it follows that the PHA may require verification for the completion of interim goals or the contract of participation. Before final disbursement of the FSS account funds to the family, the PHA may verify that the FSS family is no Ionger a recipient of welfare assistance by requesting copies of any documents which may indicate whether the family is receiving any welfare assistance, and by contacting welfare agencies [24 CFR 984.305(c)(3)]. HUD provides verification guidance in Notice PIH 2010-19. This guidance is mandatory for the public housing and housing choice voucher programs. The PHA's ACOP and/or Administrative Plan must contain verification policies following the hierarchy in this notice. The policies contained in the PHA's ACOP and Administrative Plan cover verification policies related to the FSS program in general. However, determining the need for interim disbursements may require more clarification as to what constitutes an acceptable third -party source. PHA Policy The PHA will require verification that the FSS family has completed certain interim goals, or has completed the contract of participation, and that the FSS family is no longer a recipient of welfare assistance, as relevant, before making interim and final disbursements. The PHA will follow HUD's verification hierarchy set forth in Notice PIH 2010-19 to make these verifications. However, the PHA will use a knowledgeable professional as a third -party source to verify the need for interim disbursements. Succession to FSS Account 124 CFR 984.305(d)] FSS account funds should be disbursed to the head of the FSS family. However, if the head of the FSS family no longer resides with the other family members in the public housing or the HCV -assisted unit, the remaining members of the FSS family, after consultation with the PHA, have the right to designate another family member to receive the funds. Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 6-4 Model FSS Action Plan 12.' 1.' 11 6-I.D. USE OF FSS ACCOUNT FUNDS FOR HOMEOWNERSHIP According to regulation, a public housing FSS family may use its FSS account funds for the purchase of a home, including the purchase of a home under one of HUD's homeownership programs, or other federal, state, or local homeownership programs, unless the use is prohibited by the statute or regulations governing the particular homeownership program [24 CFR 984.305(e)]. Homeownership is just one option for use of the FSS account funds. PHAs may not restrict the use of escrow funds at contract completion [Notice PIH 93-24, C-13]. r Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 6-5 Model FSS Action Plan 121 r 11 6 -LE. FORFEITURE OF FSS ACCOUNT FUNDS Amounts in the FSS account will be forfeited when the contract of participation is terminated, or when the contract of participation is completed by the family (see Section 5 -ILD. of this action plan) but the FSS family is receiving welfare assistance at the time of expiration of the term of the contract of participation, including any contract extension [24 CFR 984.305(0(1)]. Treatment of Forfeited FSS Account Funds Treatment of forfeited FSS account funds differ depending on the type of FSS program the PHA operates. For public housing FSS programs, FSS account funds forfeited by the FSS family will be credited to Other Income and will become part of Unrestricted Net Assets. Forfeited FSS account funds will be counted as other income in the determination of operating subsidy eligibility for the next budget year [24 CFR 984.305(f)(2)(i)]. In the housing choice voucher program, forfeited FSS account funds will be treated as program receipts for payment of program expenses under the PHA budget for the program, and will be used in accordance with HUD requirements governing the use of program receipts [24 CFR 984.305(f)(2)(ii)]. Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 6-6 Model FSS Action Plan 12/1/11 PART II. ESCROW FUND ACCOUNTING AND REPORTING 6-II.A. OVERVIEW Regulations set forth specific requirements involving the accounting and reporting for the FSS escrow account. This part describes those requirements and the PHA policy necessary for managing the account from the PHA perspective. 6-II.B. ACCOUNTING FOR FSS ACCOUNT FUNDS When establishing FSS escrow accounts, the PHA must deposit the FSS account funds of all families participating in the PHA's FSS program into a single depository account for each (public housing or HCV) program. In addition, the funds held in this account must be invested in one or more of the HUD -approved investments [24 CFR 984.305]. The total of the combined FSS account funds will be supported in the PHA accounting records by a subsidiary ledger showing the balance applicable to each FSS family. During the term of the contract of participation, the PHA periodically, but not less than annually, credits the amount of the FSS credit (see Section 6-I.B.) to each family's FSS account [24 CFR 984.305(a)(2)(i)]. PHA Policy The PHA will credit the amount of the FSS credit(s) to each family's account on a monthly basis. Proration of Investment Income [24 CFR 984.305(a)(2)(ii)1 Because the FSS account funds are to be invested, the investment income for those funds in the FSS account will also need to be credited to each family's account. By regulation, these funds are to be prorated and credited to each family's FSS account based on the balance in each family's FSS account at the end of the period for which the investment income is credited. PHA Policy Each month the full amount of the investment income for funds in the housing choice voucher FSS account will be prorated and credited to each family's subsidiary line item after the deduction of unpaid rent and other amounts due under the HCV -assisted lease. Reduction of Amounts Due by FSS Family [24 CFR 984.305(a)(2)(iii)] If the FSS family has not paid the family contribution towards rent, or other amounts, if any, due under the public housing or HCV -assisted lease, the balance in the family's FSS account shall be reduced by that amount (as reported by the owner to the PHA in the HCV FSS program) before prorating the interest income. If the FSS family has fraudulently underreported income, the amount credited to the FSS account will be based on the income amounts originally reported by the FSS family. © Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 6-7 Model FSS Action Plan 12/1:11 6-II.C. REPORTING ON THE FSS ACCOUNT Each PHA is required to make a report, at least once annually, to each FSS family on the status of the family's FSS account. At a minimum, the report must include [24 CFR 984.305(a)(3)1: • The balance at the beginning of the reporting period • The amount of the family's rent payment that was credited to the FSS account, during the reporting period • Any deductions made from the account for amounts due the PHA before interest is distributed • The amount of interest earned on the account during the year • The total in the account at the end of the reporting period PHA Policy The PHA will provide FSS participants at least annually and at every adjustment a statement on the status of their FSS escrow account including current escrow credit and accrued balance. %: Copyright 2011 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 6-8 Model FSS Action Plan 1211/11 Chapter 7 PORTABILITY IN HOUSING CHOICE VOUCHER FSS PROGRAMS INTRODUCTION Public Housing Agencies (PHAs) operating HCV FSS programs must be familiar with the rules and regulations regarding portability under the housing choice voucher program. As with the case of portability in the HCV program in general, the FSS family may move outside the initial PHA jurisdiction under portability procedures after the first 12 months of the FSS contract of participation [24 CFR 984.306]. In the event that an FSS family chooses to exercise portability, certain special requirements regarding the FSS program would apply. This chapter describes the obligations of the initial PHA, the receiving PHA, and the FSS family under portability, in addition to any special stipulations regarding portability in the FSS context. This chapter contains two parts: Part I: Portability in the FSS Program: This part provides a general overview of portability in the FSS program, including the residency requirements for FSS portability and management of the contract of participation when a family moves into or from another PHA's jurisdiction. Part II: The Effects of Portability on FSS Regulations and Policy: This part describes the specific ways in which portability affects different aspects of the FSS program, including the escrow account, program termination, loss of the FSS account, and termination of HCV program assistance. PART I: PORTABILITY IN THE FSS PROGRAM 7-I.A. OVERVIEW Portability is a statutory feature of the housing choice voucher program ---it is included in the law. As such, PHAs operating an HCV FSS program need to understand the effects that portability will have on HCV FSS families and program operation. This part provides a general overview of portability in the FSS program, including the residency requirements for FSS portability and management of the contract of participation when a family moves into or from another PHA's jurisdiction. S' Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use Page 7-1 Model FSS Action Plan 6.1;17 7-I.B. DEFINITIONS For the purposes of portability with regards to the FSS program, the following definitions will be used [24 CFR 982.4, 24 CFR 984.306]. • Initial PHA means both: 1. A PHA that originally selected a family that later decides to move out of the jurisdiction of the selecting PHA; and 2. A PHA that absorbed a family that later decides to move out of the jurisdiction of the absorbing PHA. • Receiving PHA means a PHA that receives a family selected for participation in the tenant - based program of another PHA. The receiving PHA either absorbs the family into its program, including issuing a voucher and providing rental assistance to the family, or bills the initial PHA for the family's housing assistance payments and the fees for administering the family's voucher. • Relocating FSS Family refers to an FSS family that moves from the jurisdiction of a PHA at least 12 months after signing its contract of participation. 7-I.C. RESIDENCY REQUIREMENTS Families participating in an HCV FSS program are required to lease an assisted unit within the jurisdiction of the PHA that selected the family for the FSS program for a minimum period of 12 months after the effective date of the contract of participation. However, the initial PHA may approve a family's request to move outside its jurisdiction under portability during this period [24 CFR 984.306(b)(1)]. PHA Policy The PHA will approve a family's request to move outside its jurisdiction under portability during the first 12 months after the effective date of the contract of participation if needed for training, education, employment, support services, or to meet personal family needs. After the first 12 months of the FSS contract of participation, the FSS family may move outside the initial PHA jurisdiction under portability procedures regardless of PHA approval [24 CFR 984.306(b)(2)]. • Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 7-2 Model FSS Action Plan 6/1/17 7-I.D. CONTRACT OF PARTICIPATION Once a family moves outside the initial PHA's jurisdiction, a determination will need to be made regarding whether the family will continue to participate in the initial PHA's FSS program or whether it will participate in the FSS program of the receiving PHA. Continued Participation in the FSS program of the Initial PHA A relocating FSS family may continue in the FSS program of the initial PHA if the family demonstrates to the satisfaction of the initial PHA that, notwithstanding the move, the relocating FSS family will be able to fulfill its responsibilities under the initial or modified contract of participation at its new place of residence. For example, this could mean that the FSS family may be able to commute to the supportive services specified in the contract of participation, or the family may move to obtain employment as specified in the contract [24 CFR 984.306(c)]. PHA Policy The PHA will allow a relocating family's request to continue in its FSS program only if the receiving PHA agrees to be responsible for completing the FSS tasks required by HUD. The family must also demonstrate to the PHA's satisfaction that, notwithstanding the move, the relocating FSS family will be able to fulfill its responsibilities under the existing or modified contract of participation at its new place of residence. Should the relocating family stay in the initial PHA's FSS program, there will be only one contract of participation. This will be the same contract as originally executed by the initial PHA [24 CFR984.306(c)(2)]. Participation in the FSS Program of the Receiving PHA When a family moves into the jurisdiction of another PHA, the relocating FSS family may participate in the FSS program of the receiving PHA if the receiving PHA allows the family to do so. However, a PHA is not obligated to enroll a relocating FSS family in its FSS program [24 CFR 984.306(d)(1)]. PHA Policy The PHA, as the receiving housing authority, will allow a relocating FSS family to participate in its FSS program so long as an open FSS slot exists. In cases where the receiving PHA allows the relocating FSS family to participate in its FSS program, the receiving PHA will enter into a new contract of participation with the FSS family for the term remaining on the contract with the initial PHA. The initial PHA will then terminate its contract of participation with the family [24 CFR 984.306(d)(2)]. Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 7-3 Model FSS Action Plan 6/1117 PART II: THE EFFECTS OF PORTABILITY ON FSS REGULATIONS AND POLICY 7-II.A. OVERVIEW The regulations set forth under the FSS program will sometimes be affected by the regulations of the public housing and housing choice voucher programs. Portability, as an integral part of the housing choice voucher program, is an excellent example of how HCV regulations can in turn affect FSS program operation. This part describes the specific ways in which portability affects different aspects of the FSS program, including the escrow account, program termination, and loss of the FSS account. 7-II.B. PORTABILITY AND THE ESCROW ACCOUNT [24 CFR 984.306(e)] The escrow account is one aspect of the FSS program that could present an issue if a participant family decides to move under portability because the family's account is administered by the initial PHA. Regardless of whether the relocating FSS family remains in the FSS program of the initial PHA or is enrolled in the FSS program of the receiving PHA, FSS regulations specify that there will be a single FSS account to be maintained by the initial PHA so long as the initial PHA is ultimately paying the housing assistance payment. However, when an FSS family is absorbed by the receiving PHA, the initial PHA transfers the family's FSS account to the receiving PHA, and the receiving PHA begins administering the account. 7 -ILC. PROGRAM TERMINATION, LOSS OF FSS ACCOUNT, AND TERMINATION OF SECTION 8 ASSISTANCE Another point of consideration for PHAs is noncompliance with the contract of participation when the FSS participant family moves outside of the PHA's jurisdiction. In such cases, noncompliance with the contract is treated the same under portability as it is if the noncompliance occurred in the initial PHA's jurisdiction. According to the regulatory language, if an FSS family that relocates to another jurisdiction is unable to fulfill its obligations under the contract of participation (or any modifications to the contract), the PHA administering the contract may terminate the FSS family from the FSS program and the family's FSS account will be forfeited [24 CFR 984.306(0(1)]. PHAs are no longer permitted to terminate a family's HCV program assistance if the family fails to meet its obligations under the contract of participation [FR Notice 12/29/14]. PHA policy regarding the consequences of noncompliance with the FSS contract of participation can be found in Section 5 -LD. of this action plan. Good cause is Iikewise defined in this section. In the event of forfeiture of the family's FSS account, the funds in the family's FSS account will revert to the PHA maintaining the FSS escrow account for the family [24 CFR 984.306(0(2)]. Copyright 2017 by Nan McKay & Associates Unlimited copies may be made for internal use. Page 7-4 Model FSS Action Plan 61./ 17 Appendix G: Waitlist Preference PART III: SELECTION FOR HCV ASSISTANCE 4-III.A. OVERVIEW As vouchers become available, families on the waiting list must be selected for assistance in accordance with the policies described in this part. The order in which families are selected from the waiting list depends on the selection method chosen by the PHA and is impacted in part by any selection preferences for which the family qualifies. The availability of targeted funding also may affect the order in which families are selected from the waiting list. The PHA must maintain a clear record of all information required to verify that the family is selected from the waiting list according to the PHA's selection policies {24 CFR 982.204(b) and 982.207(e)]. 4-III.B. SELECTION AND HCV FUNDING SOURCES Special Admissions [24 CFR 982.2031 HUD may award funding for specifically -named families living in specified types of units (e.g., a family that is displaced by demolition of public housing; a non -purchasing family residing in a HOPE 1 or 2 projects). In these cases, the PHA may admit such families whether or not they are on the waiting list, and, if they are on the waiting list, without considering the family's position on the waiting list. These families are considered non -waiting list selections. The PHA must maintain records showing that such families were admitted with special program funding. Targeted Funding [24 CFR 982.204(e)] HUD may award a PHA funding for a specified category of families on the waiting list. The PHA must use this funding only to assist the families within the specified category. In order to assist families within a targeted funding category, the PHA may skip families that do not qualify within the targeted funding category. Within this category of families, the order in which such families are assisted is determined according to the policies provided in Section 4-III.C. PHA Policy The PHA administers the following types of targeted funding: Mainstream Vouchers for Persons with Disabilities VASH-Veterans Affairs for Supportive Housing Regular HCV Funding Regular HCV funding may be used to assist any eligible family on the waiting list. Families are selected from the waiting list according to the policies provided in Section 4-III.C. 6620skaks 3 30.2020 i Copyright 2019 Nan McKay & Associates, Inc. Unlimited copies may be made for internal use. Page 4-13 Adminplan 6:1/19 4-III.C. SELECTION METHOD PHAs must describe the method for selecting applicant families from the waiting list, including the system of admission preferences that the PHA will use [24 CFR 982.202(d)]. Local Preferences [24 CFR 982.207; HCV p. 4-16] PHAs are permitted to establish local preferences, and to give priority to serving families that meet those criteria. HUD specifically authorizes and places restrictions on certain types of local preferences. HUD also permits the PHA to establish other local preferences, at its discretion. Any local preferences established must be consistent with the PHA plan and the consolidated plan, and must be based on local housing needs and priorities that can be documented by generally accepted data sources. PHA PoIicv (Effective July 1, 2020) The PHA will use the following local preferences for non-specified category vouchers for purposes of establishing priority. The local preferences are ranked differently, with the number 5 being the highest preference. Each applicant family may be granted a maximum of one local preference. The full text of local preferences is included as Exhibit 4-1 at the end of this chapter. Ranking for each preference are as follows: • PHA VAWA Emergency =5 • Families with Minor Children 3 • Homeless = 3 • Elderly - 2 • Disability = 2 • InvoluntariIy Displaced == 2 Except for the homeless preference, families can claim eligibility for any local preference any time from the date they applied up until the time their name is drawn off the waiting Iist. Preference claims will be verified once they have been drawn off the waiting Iist during the interview process. If the PHA is unable to verify the preference claim, the family will be placed back on the waiting list taking into account any change in the family's preference status order or of the assigned number without a preference. The homeless preference will be forwarded upon request to the PHA through the Coordinated Entry System (CES) that is administered by the local Continuum of Care (CoC) or a Iocal homeless provider that provides support services. The CoC or local homeless provider will be responsible for completing the referral of eligible individuals and families to the PHA and will ensure that individuals and families are document ready. Once the preference has been verified, the family will complete the full application, sign the Consent for Release of Information forms, and provide the required documents. An applicant will not be granted any Local preference for the waiting lists if any member of the family is subject to a Denial of Assistance (See Chapter 3 -III). 6620skaks 3.30.2020 Copyright 2019 Nan McKay & Associates, Inc. Unlimited copies may be made for internal use Adminplan 6 I I9 Page 4-14 The PHA may elect to open the waiting list or continue to accept applications from these applicants with preferences or funding criteria that require a specific category of family, while closing the waiting list to others. Income Targeting Requirement [24 CFR 982.201(b)(2)J HUD requires that extremely low-income (ELI) families make up at least 75 percent of the families admitted to the HCV program during the PHA's fiscal year. ELI families are those with annual incomes at or below the federal poverty level or 30 percent of the area median income, whichever number is higher. To ensure this requirement is met, a PHA may skip non -ELI families on the waiting list in order to select an ELI family. Low-income families admitted to the program that are "continuously assisted" under the 1937 Housing Act [24 CFR 982.4(b)], as well as low-income or moderate -income families admitted to the program that are displaced as a result of the prepayment of the mortgage or voluntary termination of an insurance contract on eligible low-income housing, are not counted for income targeting purposes [24 CFR 982.201(b)(2)(v)]. PHA Policy The PHA will monitor progress in meeting the income targeting requirement throughout the fiscal year. Extremely low-income families will be selected ahead of other eligible families on an as -needed basis to ensure the income targeting requirement is met. Order of Selection The PHA system of preferences may select families based on local preferences according to the date and time of application or by a random selection process (lottery) [24 CFR 982.207(c)]. If a PHA does not have enough funding to assist the family at the top of the waiting list, it is not permitted to skip down the waiting list to a family that it can afford to subsidize when there are not sufficient funds to subsidize the family at the top of the waiting list [24 CFR 982.204(d) and (e)]. PHA Policy Families will be selected from the waiting list based on the targeted funding or selection preference(s) for which they qualify, and in accordance with the PHA's hierarchy of preferences, if applicable. Within each targeted funding or preference category, families will be selected in numerical order based on the numbers that were assigned to each application, by lottery, at the time the applications were placed on the waiting list. Documentation will be maintained by the PHA as to whether families on the list qualify for and are interested in targeted funding. If a higher placed family on the waiting list is not qualified or not interested in targeted funding, there will be a notation maintained so that the PHA does not have to ask higher placed families each time targeted selections are made. 4-III.D. NOTIFICATION OF SELECTION When a family has been selected from the waiting list, the PHA must notify the family [24 CFR 982.554(a)]. 6620skaks 3.30 2020 Copyright 2019 Nan McKay & Associates, Inc. Unlimited copies may be made for internal use. Page 4-15 Adminplan 6,11/19 EXHIBIT 4-1: LOCAL PREFERENCES • Elderly Preference: This preference is extended to elderly person or families with an elderly member as defined in this plan. • Disability Preference: This preference is extended to disabled persons or families with a disabled member as defined in this plan. The PHA will require appropriate documentation from a knowledgeable professional. The PHA will not inquire as to the nature or extent of the disability. An award letter or other proof of eligibility for Social Security Disability or Supplemental Security Income will be acceptable. • Involuntary Displacement Preference: Involuntarily displaced applicants are applicants who have been involuntarily displaced and are not living in standard, permanent replacement housing, or will be involuntarily displaced . The displacement must have occurred within 24 months of requesting the involuntary displacement preference. Also, the PHA will offer a preference to any family that has been terminated from its HCV program due to insufficient program funding. Families are considered involuntarily displaced if they are required to vacate housing as a result of: 1. A disaster (e.g. fire, flood, earthquake, lava, etc) that has caused the unit to be uninhabitable. 2. Federal, state or local governmental action related to code enforcement, public improvement or development, Families who claim they are being or have been displaced due to either a disaster or government action: written verification by the displacing unit or agency of government, or by a service agency such as the Red Cross. • Homeless Preference: Contingent upon funding, the PHA will give preference to homeless applicants. Each fiscal year, which is defined as the period from July 1st — June 30th, the PHA will give a preference to no more than 100 applicants or 25% of all applicants drawn (whichever is Tess) meeting all of the following criteria: 1. Meet the HUD definition of homeless: a. Individual or family who lacks a fixed, regular, and adequate nighttime residence, meaning: (i) Has a primary nighttime residence that is a public or private place not meant for human habitation; (ii) Is living in a publicly or privately -operated shelter designated to provide temporary living arrangements (including congregate shelters, 6620skaks 3.30.2020 Copyright 2019 Nan McKay & Associates, Inc Unlimited copies may be made for internal use. Page 4-20 Adminplan 611:19 transitional housing, and hotels and motels paid for by charitable organizations or by federal, state and local government programs); or (iii) Is exiting an institution where (s)he has resided for 90 days or less and who resided in an emergency shelter or place not meant for human habitation immediately before entering that institution 2. Are referred to the PHA by the local CoC Coordinated Entry System (CES) or local homeless service provider with whom OHCD has executed a Memorandum of Understanding (MOU) outlining the provider's responsibilities with respect to the provision of housing search assistance and supportive services for the referred household. 3. The CoC or local homeless service provider will also provide supportive services to help the household maintain and comply with HCV rules. While a referral from the CoC or local homeless service provider is required for this preference, use of the offered supportive services is not a requirement. The choice of the applicant to refuse the offered services will not jeopardize any housing assistance for which they are eligible. The PHA will execute a MOU with the CoC which will serve as the primary point of contact for communicating homeless referrals to the PHA. The PHA reserves the right to establish additional MOU's as necessary to ensure that homeless applicants have the opportunity to apply for housing assistance under this preference. If it is determined that an applicant referred by the CoC or local homeless service provider, as described above, does not meet the criteria described therein, the applicant will not receive the preference. The applicant will return to their lottery position on the waiting list without the homeless preference. If the PHA denies an applicant's homeless preference claim, the PHA will notify the applicant and referring service provider in writing, including the reason(s) for the preference denial. Applicants have the right to appeal the denial of eligibility for the homeless preference using the established process for informal hearings. Participants in the PHA's HOME Tenant -Based Rental Assistance (TBRA) program, will also be included as a priority group as part of this homeless preference and meet all of the following criteria: 1. Are on the Housing Choice Voucher (HCV) waiting list after July 1, 2020 2. Received rental assistance on the HOME-TBRA program for at least 12 cumulative months 3. Are not in the initial term of a lease agreement 4. Participant(s) household has complied with the housing program requirements and all provisions of the lease agreement. These individuals and families will not be required to be referred through the CoC referral process. ® Copyright 2019Nan McKay & Associates, Inc. Unlimited copies may be made for internal use. Page 4-21 Adminplan 6/1/19 • Families with Minor Children Preference: The PHA will give preference to families with minor children. A minor child is child under 18 who meets HUD and the PHA's definition of a family member (See Section 3.I.B for the definition of Family Members). • Minor children of a live-in aide do not qualify the family for this preference • Minor children that are foster children of an authorized adult member of the assisted family do not qualify the family for this preference • PHA VAWA Emergency Preference: The PHA will give preference to families living in a PHA owned property or who receive Project Based Voucher (PBV) assistance, who are victims of domestic violence, dating violence, sexual assault or stalking and meet the eligibility requirements outlined in the PHA's VAWA emergency Transfer Move Plan. 6620skaks 3.30.2020 ki,` Copyright 2019 Nan McKay & Associates. Inc. Unlimited copies may be made for internal use. Page 4-22 Adminplan 6/1/19 Appendix H: Public Hearing Narrative PUBLIC NOTICE COUNTY OF HAWAI' 1 5- YEAR AND ANNUAL PHA PLAN for FISCAL YEAR 2020 HOUSING CHOICE VOUCHER PROGRAM Notice is hereby given that the Office of Housing and Community Development, Existing Housing Division pursuant to 42 USC § 1437c -1(l)(5) through 24 CFR § 903.23(e) will hold a public hearing on the County's proposed Public Housing Agency (PHA) 5 -year Plan and Annual Plan for the fiscal year beginning July 1, 2020. The public hearing will be held on: 9:00 AM. Monday. March 23. 2020 Office of Housing and Community Development 1990 Kino' ole Street, Suite 104, Hilo -and by video conference - Office of Housing & Community Development West Hawai' i Civic Center 74-5044 Ane Keohokalole Highway Building B., 2nd Floor Kailua - Kona, HI 96740 The public hearing will be conducted for the purpose of furnishing citizens with information on the status of the mission, goals and objectives of the 5 -year PHA plan that serve the need of low-income and very low-income families during the next year. The PHA Annual Plan provides details about the agency's immediate operations, program participants, programs and services and strategy for handling operational concerns, participant concerns, programs and services for the upcoming fiscal year. All interested persons are invited to attend and to state their views on the proposed plans either orally or in writing. Written testimonies prior to the hearing would be appreciated. The OHCD will consider any comments and views expressed by citizens on the proposed PHA Plans and may modify the Plans if it deems appropriate. Public Comment Period The proposed 5 -year PHA Plan and Annual Plan will be available for public review and comment from February 7, 2020 through March 23, 2020, at the Office of Housing and Community Development, Monday through Friday, 7:45 a.m. to 4:30 p.m, except holidays. The OHCD office locations are: Hilo: 1990 Kino' ale Street, Suite 102 Kona: West Hawai' i Civic Center, 74-5044 Ane Keohokalole Highway, Bldg B., 2nd Floor The Plans will also be available on-line at: http://www.Hawaiicounty.gov/office-of- housing/ Citizens who wish to comment on the proposed plans may submit their comments in writing or by fax (959-9308) or by email (sec8info@hawaiicountv.gov) to the OHCD by 4PM, March 23, 2020, in order for them to be considered. Citizens may also testify at the hearing on the above dates. Accommodations for persons with special needs and interpreters for non-English speaking citizens will be available at all public hearings and sessions upon written request 10 business days prior to the meeting date. Duly submitted by Duane T. Hosaka Housing Administrator January 27, 2020 (HTH1263206 2/7/20) Public Hearing PHA FY 2020 Annual Plan and PHA 5 -year plan The public hearing for the Draft PHA FY 2020 Annual Plan and the Draft PHA 5 -year plan FY 2020-2025 was held on March 23, 2020 at 9:03 am. The public hearing notice was published in the Hawaii Tribune Herald and West Hawaii Today on February 7, 2020, Friday. The written comment period ended at 4:30 pm on Friday, March 23, 2020. The Office of Housing and Community Development received two (2) written comments during this period (see attached). The presiding officer was Kori Koike Smith, Housing Specialist V. The public hearing was called to order at 9:03 am. As there were no oral challenges to the draft plans and no oral written testimony given, the public hearing as of0cially adjourned at 9:18 am. 6613skaks Public Hearing Regarding PHA 5 -year and Annual Plan for FY 2020 March 23, 2020 — 9:00 am — Hilo & Kona (by video conference) Good Morning. It is now 9:03 am. My name is Kori Koike Smith and beside me is Garrett Uejo. We represent the County of Hawaii, Office of Housing and Community Development, Existing Housing Division. The public hearing is being held in Hilo and in Kona by video conference. In Hilo at 1992 Kinoble Street, Suite 104, and in Kailua-Kona at the West Hawaii Civic Center, Building B. 2nd Floor. The purpose of this public hearing is to take public testimony on the proposed PHA Annual Plan for the Fiscal Year 2020 and the PHA 5 -year Plan for Fiscal Years 2020-2025. The OHCD also proposes significant changes, these changes include: • Replacing and repealing the FSS action plan • Modifying the OHCD Administrative Plan, Chapter 4 regarding local waitlist preferences I now declare this hearing open. We will now begin taking testimony. ******************************************************************************************* There is no one here to present public testimony. The time is now 9:05 am. I will recess the public hearing for ten (10) minutes. During this recess, I will not take public testimony. It is now 9:18 am and there is no one here to provide testimony for the proposed PHA 5 -year and Annual Plan for fiscal year beginning July 1, 2020. 1 declare the hearing to be closed. 66l3skaks DRAFT FY 2020 PHA Annual Plan and 5 -year Pian Emailed Comments Comment #1: "Essentially the 1st tier would be a waiting list that was always open and that people could register for at any time. It would require people to re -register yearly or they would be taken off of the waiting list, but since the waitlist itself is not managed by time of sign- up, even if someone misses their date, it would not really matte much. The 2nd tier would be what you are using now, except, when it opened up to take more, it would take people from the 1st tier in a lottery fashion. Benefits of a system like this include all people interested can apply for the wait list right away. The reapplication process ensures the list stays current. Servers will not be overloaded at times of reopening the tier 2 wait list. Helps keep the system Tess random, for who gets on and who doesn't (right place right time thing)." Comment #2: "March 23, 2020 To: Duane Hosaka Housing Administrator Office of Housing and Community Development 1990 Kino'ole Street, Suite 102, Hilo, Hawai'i 96720 From: Sharon L. Hirota Executive Assistant to Mayor Harry Kim Re: Public Comment — 5 -Year and Annual PHA Plan for Fiscal Year 2020 Housing Choice Voucher Program Thank you very much for providing an opportunity to submit public comment on the 5Year and Annual PHA Plan for Fiscal Year 2020. 5 -Year PHA Plan (Streamline Version) 1. The Office of Housing and Community Development should apply for all Housing Choice Vouchers that become available. Special focus should be made on vouchers that specifically provide preference for the elderly, non -elderly and disabled, veteran's, homeless, victims of domestic violence, foster youth, family unification and trafficking. 2. Continue to find opportunities to connecting with existing homeownership programs to increase the number of individuals who become first time homeowners. 6613skaks Annual PHA Plan 1. Local Preferences [24 CFR 982.207; HCV p. 4-161 In reference to the proposed changes to the Administrative Rules as it relates to the Preference for its Waiting List: a. Preference should be to individuals experiencing homelessness as defined by the US Department of Housing and Urban Development. b. The PHA should work directly with in partnership with the local, Continuum of Care, Community Alliance Partners and its existing federally mandated Coordinated Entry System in the selection of eligible applicants. c. Allocation of voucher resources should be allocated to eligible and document ready, as defined by program rules, with no more than 25% of the allocation to assist individuals and families eligible for Permanent Supportive Housing, no more than 50% for those eligible for Rapid Rehousing and no more than 25% for those eligible or existing from Transitional Housing. d. Case management and supportive services will be determined based on criteria as set by PSH, RRH and TR funder requirements. Case Management and supportive is highly recommended but not a requirement for continued participation in the Section 8 program. e. Families existing from the HOME funded Tenant Based Rental Assistance program should be eligible for a preference consideration." 6613skaks