HUD Recap Office Issues RAD Choice Mobility Guidebook

HUD’s Office of Recapitalization (Recap) issued a RAD Choice Mobility Guidebook to promote effective implementation of residents’ “Choice-Mobility” rights in the Rental Assistance Demonstration (RAD) program. The Guidebook was written with significant input from the Poverty & Race Research Action Council (PRRAC), which has advocated extensively for residents with Housing Choice Vouchers (HCVs or vouchers) to be able to use their vouchers in better-resourced neighborhoods that have lower racial and ethnic concentrations of poverty. Choice-Mobility is a term created by HUD for RAD and refers to the right of residents to request to move with a regular HCV after one or two years if they are living in former public housing properties that converted to the Project-Based Voucher (PBV) or Project-Based Rental Assistance (PBRA) programs as a result of RAD.

Although Choice-Mobility has been an official RAD requirement from the beginning of the program, a 2019 study revealed that nearly 50% of RAD residents were not aware of their right to move, and that many public housing agencies (PHAs) had not developed Choice-Mobility policies and procedures. The purpose of the Guidebook is to provide PHAs, owners, and managers of RAD properties with RAD’s Choice-Mobility requirements, along with a set of non-required “best practices.” To assist PHAs, owners, and managers, the Guidebook’s appendix has eight sample fact sheets, forms, checklists, and templates.

The Guidebook describes the basics of Choice-Mobility and offers suggestions about structuring a Choice-Mobility policy, notifying residents about their Choice-Mobility rights, managing residents’ requests for a Choice-Mobility voucher, creating and maintaining a Choice-Mobility Priority list, treating “turnover caps,” and ensuring coordination between PHAs and owners/managers of PBRA properties.

Residents whose public housing development has converted to PBV through RAD are eligible to obtain an HCV beginning one year after their development converts to PBVs or one year after they move into the property, whichever comes later. Because a household transitioning from a PBV to an HCV continues to be a participant in the HCV program, it is not subject to any screening requirement. Residents whose public housing development has converted to PBRA through RAD are eligible to obtain an HCV beginning 24 months after their development converts to PBRA or 24 months after they move into the property, whichever comes later. PBRA households must qualify for assistance under their PHA’s HCV program (e.g., meet income requirements).

The right to a Choice-Mobility voucher does not expire as long as a resident still lives in the RAD property. Also, if a resident with a Choice-Mobility voucher does not use it to lease a unit on the open market within a PHA’s prescribed HCV search times (generally 60 days), they remain eligible for a Choice-Mobility voucher in the future, as long as they continue to live in the same RAD project.

Access to a RAD Choice-Mobility voucher depends on a regular HCV becoming available (or “turning over”). RAD Choice-Mobility residents go to the top of the HCV waiting list. The regular Project-Based Voucher (PBV) program, created in 2005, established the right to move with an HCV. Therefore, many PHAs might have existing lists of regular PBV households who have requested to move with an HCV. A RAD resident does not have priority for receiving an HCV over a non-RAD PBV resident. Therefore, the Guidebook suggests PHAs create a single priority list for all requests from PBV developments (both RAD and non-RAD) and RAD PBRA developments, sorted by the date and time a resident requested an HCV.

The Guidebook provides many good suggestions regarding informing residents of their Choice-Mobility rights. To ensure that residents are fully aware of and understand their mobility rights, PHAs are encouraged to provide clear information about Choice-Mobility to residents at multiple times in the RAD process. At the beginning of the RAD process, the RAD Notice (the official document that PHAs and owners must follow as if it is a regulation) specifies that before even submitting an application to participate in RAD, a PHA must provide written notice in the form of a “RAD Information Notice” (RIN) to residents of public housing projects to inform them of the PHA’s intent to apply for RAD conversion and of their rights in connection with a proposal. The discussion of resident rights in the RIN must include information on a resident’s ability to request and move with a Choice-Mobility voucher.

Before a PHA applies for RAD but after it issues a RIN, the RAD Notice states that the PHA must hold two meetings with residents of projects proposed for conversion to discuss conversion plans and resident rights, including the Choice-Mobility right. Before a RAD conversion deal “closes” but after a RAD Conversion Commitment (RCC) is issued, a PHA must notify residents that conversion has been approved by Recap and, among other things, also inform them about how they can use Choice-Mobility.

After RAD conversion, PHAs are encouraged to give all residents a plain language written notice of their Choice-Mobility rights at multiple points in time. It is a best practice to provide a Choice-Mobility notice to new residents at lease signing. Subsequently, Choice-Mobility a notice could be provided at least annually, including at a household’s income recertification. The Guidebook encourages PHAs to provide a plain-language notice to each resident at least four months prior to the date they would first become eligible for an HCV.

Read the RAD Choice Mobility Guidebook at: https://tinyurl.com/36kd7wyb

More RAD information oriented to residents is on Recap’s RAD Resident Information webpages

Read Recap’s RAD webpage at: https://www.hud.gov/RAD

Read more about RAD on page 4-46 of NLIHC’s 2023 Advocates’ Guide, and on NLIHC’s public housing webpage