HUD is seeking comments regarding modest changes to the Public Housing Agency Plan (PHA Plan) template. HUD documents, such as the PHA Plan template, are subject to periodic renewal and review by the Office of Management and Budget; the current PHA Plan template expires on April 30.
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 fewer than 550 public housing units and housing choice vouchers, combined, are called “qualified” PHAs. Those with more than 550 such households are called “non-qualified” PHAs and must also develop an Annual Plan, which is a gathering together of a PHA’s key policies (such as those applying to admissions, income targeting, rents, pets, etc.) and program intentions (such as demolition or disposition). However, only a short PHA Plan template has to be submitted to HUD each year. Residents are often only aware of the template, not all of the documents which comprise a genuine Annual PHA Plan.
HUD proposes a major visual change for the template, listing all 19 required PHA Plan elements that non-qualified PHAs must have as part of their Annual Plans. This is a modest improvement because it offers residents information about what the required elements are; the existing template merely directs PHAs to identify elements that were revised during the year. However, the proposed template also declares that a description of the actual change(s) is not required. Consequently, residents will have to sift through a document word-for-word to detect changes.
NLIHC has long urged HUD to require the Annual Plan to identify changes (see Memo, 9/15/06, 5/11/07, 8/31/07, and 11/21/08). In general, NLIHC has also expressed concern that resident involvement in the PHA Plan process will diminish due to the loss of guidance in the streamlined PHA plan template, which makes it more 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.
Three other proposed changes include:
1. All PHAs, qualified and non-qualified, must state in their 5-Year Plans the goals, objectives, policies, or programs that will enable the PHA to serve the needs of child and adult victims of domestic violence, dating violence, sexual assault, or stalking.
2. Non-qualified PHAs must have a copy of their poverty deconcentration policy which aims to bring higher income residents into lower income projects and help lower income residents live in higher income projects. Unlike the 19 PHA Plan elements, the deconcentration policy must be sent to HUD for review.
3. PHAs with “standard” or “troubled” performance designations must include any memorandum of agreement (MOA) with HUD that specifies how the PHA will improve performance.
Most of the other changes in the template weave in features of the 2008 Small Public Housing Authorities Paperwork Reduction Act which exempted qualified PHAs from preparing an annual PHA Plan.
Comments are due June 13, 2011. The proposed PHA Plan template is http://www.nlihc.org/doc/Proposed_PHA_Plan_Template.pdf, and the current template is http://www.nlihc.org/doc/Current_PHA_Plan_Template.pdf. HUD’s Office of Public and Indian Housing published a Notice of Proposed Information Collection for Public Comment in the Federal Register on April 13, 2011, http://edocket.access.gpo.gov/2011/pdf/2011-8778.pdf.
For more about the PHA Plan in general, see page 174 of NLIHC’s 2011 Advocates’ Guide at www.nlihc.org