HUD issued a Notice to help public housing agencies (PHAs) understand the Community Service and Self-Sufficiency Requirement (CSSR) for public housing residents so that PHAs can more effectively administer the requirement. In response to a report from HUD’s Office of the Inspector General on February 13, 2015 that was critical of how CSSR has been implemented, the Office of Public and Indian Housing (PIH) issued Notice PIH-2015-12 on August 13.
The Quality Housing and Work Responsibility Act of 1998 requires every adult resident of public housing to contribute eight hours of community service per month or to participate in an economic self-sufficiency program for eight hours per month. A public housing resident could meet the requirement by performing eight hours of some combination of community service or economic self-sufficiency activity. The requirement is not restricted to a precise eight hours per month; a resident could comply by performing any amount of hours per month, as long as at least 96 hours are accumulated by their annual certification.
Community service is defined as “The performance of voluntary work or duties that are a public benefit, and that serve to improve the quality of life, enhance resident self-sufficiency, or increase resident self-responsibility in the community.” The Notice lists examples of eligible community service activities such as serving at schools, Head Start Programs, child-care centers, or senior centers; assisting at nonprofits dedicated to special needs populations, environmental improvement, or the performing arts; improving conditions at their public housing development; and participating on resident councils or the Resident Advisory Board. A PHA may not substitute community service for work ordinarily performed by a PHA employee.
Examples of eligible self-sufficiency activities include job readiness or training, higher education, apprenticeships, substance abuse counseling, literacy classes, English proficiency classes, and budgeting counseling.
The Notice provides examples of public housing residents who are exempt from the requirements, including people 62 years old or older, people with disabilities, and people engaged in work activities. The Notice provides a list of work activities, including employment, vocational education, on-the-job-training, and education directly related to employment. PHAs are encouraged to use 30 hours per week as the minimum number of hours for a work activity to be eligible.
PHAs must develop a policy for administering the CSSR and include the policy in the PHA’s Admissions and Continued Occupancy Policies (ACOP) document. The ACOP must describe the PHA’s responsibility for administering the CSSR, eligible and non-eligible activities, exemptions from the requirement, and compliance review standards.
PHAs may not evict a family due to an adult’s failure to comply with CSSR. However, if a tenant does not comply, the PHA must provide the tenant written notice indicating that the PHA will not renew the household’s lease at the end of the current 12-month lease, unless the tenant enters into a work-out agreement. The Notice details tenant procedural rights such as the right to request a grievance hearing and to be represented by counsel.
Notice PIH-2015-12 is at http://portal.hud.gov/hudportal/documents/huddoc?id=pih2015-12.pdf