In response to a HUD request for comment regarding proposed changes to the PHA Plan template (see Memo, 4/15), NLIHC urged HUD to return to the more complete PHA Plan template used prior to 2008. Since 2006 NLIHC has registered concern that HUD’s “streamlining” of the PHA Plan template would greatly diminish its value as a planning tool for public housing and voucher residents (see Memo, 9/15/06, 9/29/06, 5/11/07, 8/31/07, and 11/21/08). The loss of guidance in the PHA Plan template makes it difficult for residents and others to understand the PHA Plan process, engage in it, and access information associated with the 19 statutorily required PHA Plan components.
All PHAs, regardless of size, must develop a 5-Year PHA Plan that describes the PHA’s overall mission and goals regarding the housing needs of low income families in its jurisdiction. PHAs with a combination of more than 550 public housing units and housing choice vouchers (called “non-qualified” PHAs) have to develop an Annual Plan, which gathers together a PHA’s key policies (such as those regarding admissions, income targeting, rents, pets, etc.) and program intentions (such as demolition or disposition). However, since 2008 only a short PHA Plan template has to be submitted to HUD each year. Residents are often aware only of the template, and not all of the documents that comprise a genuine Annual PHA Plan. (PHAs with fewer than 550 units or vouchers are called “qualified” PHAs.)
NLIHC’s comment letter welcomed the latest proposal to make a very modest visual improvement to the PHA Plan template by listing the 19 statutory elements non-qualified PHAs must have as part of their Annual Plans. This offers public housing residents and the larger community a hint about the required elements.
However, the proposed template and instructions merely require PHAs to check whether an element has changed, but they do not have to describe the changes themselves. Consequently, residents would have to read line-by-line through both the old and new documents in order to detect changes. To foster transparency and to ensure public accountability, NLIHC suggested that the template and instructions require precise indications of any changes.
Other recommendations included requiring PHAs to:
- Post complete versions of each of the 19 required elements on their websites.
- Submit for HUD review any required element challenged by residents or others in the community, rather than limiting review to elements challenged only by the Resident Advisory Board (RAB).
- Attach any Memorandum of Agreement for improving performance if the PHA is rated “Standard” and “Troubled.”
The NLIHC comment letter is at http://www.nlihc.org/doc/NLIHC_Comment_Letter_PHA_Plan.pdf
More information about the PHA Plan is on page 174 of NLIHC’s 2011 Advocates’ Guide, at www.nihc.org