HUD published for comment a second revision to Form 50900, the required Annual Plan and Performance Report for public housing agencies (PHAs) participating in the Moving to Work (MTW) demonstration program. In addition to serving as a substitute PHA Plan for MTW agencies, the data and information on the form should assist HUD in determining PHA compliance with the MTW statute and in evaluating the demonstration.
NLIHC worked with the National Housing Law Project and members of the Housing Justice Network (HJN), an informal network of housing advocates and residents, to write a 21-page letter commenting on HUD’s initial set of proposed changes (see Memo, 7/22).
NLIHC has long been concerned about the MTW demonstration because of the ability of MTW PHAs to set time limits, impose work requirements, and establish rent policies making rents unaffordable.
The current revision does not adequately address advocates’ comments from July, but it does make a few minor improvements recommended in the HJN letter. One set of changes reflects an important suggestion HJN made based on the MTW statute, which requires that at least 75% of assisted households at participating PHAs have incomes below 50% of the area median income (AMI). The statute also requires these PHAs to continue to assist substantially the same total number of low income households and to maintain a comparable mix of families by family size, as would have been served prior to the PHA participating in MTW. In response to the HJN comments, the new Form 50900 includes two new subsections. One requires MTW PHAs to show the percentage of assisted households with incomes below 50% AMI in each year, starting in 2011. The other requires a comparison of the number of households assisted and the family size categories assisted in the reporting year with benchmark numbers when the PHA entered the MTW demonstration.
The HJN letter urged HUD to add instructions to guide PHAs in conducting meaningful resident participation, and to include a detailed community involvement section for both the Annual Plan and the Annual Report. However, the second version of Form 50900 merely asks MTW agencies to indicate the beginning and ending dates when the draft Plan was available for public view, and the dates and locations of public hearings and the number of people attending. There is no reference to public accountability regarding the Performance Report.
Comments are due December 19, 2011.
The Federal Register Notice is at: http://www.gpo.gov/fdsys/pkg/FR-2011-11-18/pdf/2011-29917.pdf
The second revision of Form 50900 is at: http://nlihc.org/doc/MTW_50900_Rev_ 10-27-11.pdf
The July 15 HJN letter is at: http://www.nlihc.org/doc/MTW_Comment_Letter_7-15-11.pdf