HUD’s Office of Pubic and Indian Housing issued a preview of Notice PIH 2017-1 requesting public housing agencies (PHAs) to apply for participation in the first group of the newly expanded Moving to Work (MTW) demonstration program. The first 30 MTW PHAs will evaluate the overall effects of MTW flexibility provided to PHAs, comparing how MTW affects the three statutory objectives of MTW: cost effectiveness, resident self-sufficiency, and housing choice.
The “Consolidated Appropriations Act of 2016” authorized HUD to expand the MTW demonstration program to an additional 100 high performing PHAs over a seven-year period (see Memo, 12/21/15). PHAs will be added to the MTW demonstration in annual cohorts, each of which will be overseen by a research advisory committee to ensure the demonstrations are evaluated with rigorous research protocols, quantitative analysis, and comparisons to control groups. Each year’s cohort of MTW sites will be directed by HUD to test one specific policy change.
Of the 100 new PHA MTW sites, the statute requires that no fewer than 50 PHAs must administer up to 1,000 combined public housing and voucher units, no fewer than 47 must administer between 1,001 and 6,000 combined units, and no more than three can administer between 6,001 and 27,000 combined units. Notice PIH-2017-1 adds that five must be PHAs with Rental Assistance Demonstration (RAD) portfolio awards (a RAD conversion made up of more than one public housing development).
The first cohort of 30 MTW agencies will evaluate the overall effects of MTW flexibility on a PHA and the residents it serves. MTW flexibility allows a PHA to combine its public housing capital and operating funds with its Housing Choice Voucher (HCV) funds and to use these funds interchangeably and for non-traditional uses. MTW also allows a PHA to seek HUD approval for relief from some regulatory requirements. HUD will compare outcomes related to the three MTW statutory objectives - cost effectiveness, self-sufficiency and housing choice - between PHA applicants that receive MTW designation and a control group of PHA applicants that do not receive MTW designation.
The underlying evaluation question for the first cohort is, “What is the impact of MTW flexibility?” The outcome measures will be aligned with the MTW statutory objectives of:
- Cost Effectiveness. For example, how does MTW impact the PHA’s staffing, resources allocation, and leveraging of other funds?
- Self-Sufficiency. For example, how does MTW impact who is served, for how long, and what happens after they leave assistance?
- Housing Choice. For example, how does MTW impact housing quality, neighborhood safety, and access to community resources?
Future cohorts will evaluate:
- Different rent reform models that may or may not be income-based. Models could include flat rents, tiered rents, and stepped-up rents. It is also possible that the interaction of rent reforms with or without work requirements and/or time limits may be evaluated.
- Work requirements without additional rent reforms or time limits but with applicable support services provided by the PHA or a partner.
- Means to improve landlord participation in the HCV program through incentives such as participation payments, vacancy payments, and alternate inspection schedules.
The first cohort will consist of 30 PHAs with 1,000 or fewer aggregate public housing and HCV units. All PHA applicants HUD determines to be eligible will be separated into five geographic areas: Northeast (HUD Regions 1, 2, 3), Southeast (HUD Region 4), Midwest (HUD Region 5), Southwest (HUD Regions 6, 7), and West (HUD Regions 8, 9, 10). A lottery will then be conducted for each geographic area to randomly assign applicant PHAs to receive MTW designation or to be in the control group without MTW designation. The target number of MTW designations by region are: five in the Northeast, seven in the Southeast, five in the Midwest, ten in the Southwest, and three in the West. If a PHA is not selected for the first cohort, it may still apply to a future cohort.
PHAs are required to publish a public notice, available for at least 30 days, that a hearing will be held about an MTW application. In advance of the public hearing, PHAs must notify public housing and HCV residents of the intention to apply for MTW status and hold two separate meetings for residents. The PHA’s Board of Directors may not approve an MTW application until 15 days after the public hearing.
An application must discuss any major plans the PHA has for its housing stock as a result of its participation in the MTW demonstration. The PHA must also describe the types of activities it intends to implement with MTW flexibility and why these activities are appropriate. However, the Notice does not require the application to indicate discreet activities.
An application must discuss how the PHA engaged public housing and voucher residents, as well as the broader community and stakeholders, including racial and ethnic minorities, persons with limited English proficiency, persons with disabilities, and groups representing such persons. The application must include the dates, location, and attendance information about the two required public meetings and the public hearing. The PHA must discuss how it sought proactive engagement before and during the creation of the application and input on drafts and finished products. The PHA must also describe how suggestions and feedback resulting from these engagements were incorporated into the application.
An application must discuss how the PHA plans to continue to engage public housing and voucher residents, the broader community, and stakeholders, in the implementation and development of its MTW program. It must describe any planned affirmative outreach and engagement efforts with racial and ethnic minorities, persons with limited English proficiency, persons with disabilities, and groups representing such persons.
The structure of the MTW expansion is still under development by HUD. The Notice states that HUD is attempting to balance giving PHAs maximum flexibility with maintaining key protections for assisted households and to conduct robust evaluation of each demonstration. The MTW demonstration statute requires PHAs to:
- Ensure that at least 75% of the households assisted are very low income (income at or less than 50% of the area median income);
- Continue to assist substantially the same total number of low income households as would have been served without MTW status; and
- Maintain a comparable mix of households by household size as would have been served without MTW status.
HUD will describe a new program structure in an Operations Notice published at a later date. HUD solicited comments regarding an Operations Notice in the Federal Register on January 23. After considering public comments HUD will publish a final Operations Notice. That Notice will include a full list of available MTW waivers.
Notice PIH 2017-1 is scheduled to be formally issued on January 23. The preview version is at: http://bit.ly/2j3qvWf.
HUD’s solicitation of comments regarding an MTW Expansion Operations Notice is at: http://bit.ly/2j3meSJ