HUD’s Office of Inspector General (IG) found that the Spokane Housing Authority failed to follow the Rental Assistance Demonstration (RAD) permanent relocation requirements when converting the 50-unit Parsons Apartments from public housing to Section 8 Project-Based Rental Assistance. The Authority did not properly plan for and execute permanent resident relocation. As a result, two of five households that moved during the IG’s study period were required to permanently relocate without the households’ written consent.
Two of the many tenant protections that public housing leaders fought to secure when HUD proposed and Congress approved the demonstration program in 2012 were the residents’ right to return to their former public housing homes and a prohibition of re-screening when residents did return after improvements were made through RAD. These crucial rights were informed by residents not being able to return after improvements made by the HOPE VI program in the late 1990s and early 2000s.
RAD implementation requirements are detailed in Notice PIH 2012-32 REV3. According to the Notice, a household can only voluntarily move from their public housing development after RAD conversion. In addition, in order to permanently relocate a household, a public housing agency (PHA) must obtain a household’s written consent to receive permanent relocation assistance. If the RAD conversion plan entails permanent relocation and a household does not provide written consent, then the PHA must alter its conversion plan and accommodate the household in the converted development.
The RAD Notice also requires a PHA to complete a relocation plan checklist and submit it to HUD as part of its Financing Plan. The checklist has a field to describe relocation plans, whether for temporary or permanent relocation. Spokane’s checklist indicated that there would not be permanent relocation.
The Parsons Apartment RAD received Low Income Housing Tax Credits (LIHTCs); therefore, the PHA undertook resident income verification for LIHTC purposes. Two households were found to be over-income and the PHA required them to permanently move without obtaining voluntary, written consent.
The IG also found that the Spokane Housing Authority lacked controls to ensure that its property management staff applied the RAD relocation requirements. The staff were experienced with LIHTC processes but did know now about the RAD right to return and prohibition of re-screening. Authority executives did not effectively monitor how property management staff processed RAD relocations.
The IG report is at: https://bit.ly/2vUKtuE
More about RAD is on page 4-15 of NLIHC’s 2018 Advocates’ Guide.