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Robeson County Housing Authority non-profit Logo
Robeson County Housing Authority Non-profit Logo

MTW Plan

PHA Name: Robeson County

PHA Code: NC084
MTW Supplement for PHA Fiscal Year Beginning: 07/01/2023
PHA Program Type: Public Housing (PH) only
MTW Cohort Number: MTW Flexibility for Smaller PHAs
MTW Supplement Submission Type: Annual Submission

DRAFT

B. MTW Supplement Narrative

Introduction

Robeson County Housing Authority (RCHA) is an approved Moving to Work (MTW) agency and as such has broad authority to propose regulatory waivers designed to incentivize family self-sufficiency, promote housing choice, and improve cost-effectiveness through regulatory simplification.

In 2023, the RCHA will continue the majority of the MTW activities proposed in its approved 2022 MTW Supplement. The following are modifications in the 2023 MTW Supplement:

  • The RCHA removed the Step Rent Waiver because the agency will implement Triennially Re-certifications for all 290 households.
  • The RCHA added the Utility Reimbursements waiver for public housing.
  • The RCHA added the Family Self-Sufficiency with MTW Flexibilities Waiver.

The RCHA was awarded the Family Self-Sufficiency (FSS) grant on January 26, 2023. The agency wanted to implement flexibility at the inception of the Grant to avoid being regulated to establish a traditional MTW FSS program in the future.

MTW Goal 1: Reduce Cost and Achieve Greater Cost-Effectiveness in Federal Expenditures

Alternative Reexamination Schedule

  • RCHA will reduce the frequency of tenant reexaminations to Triennially for all families allowing one interim adjustment per year at the request of the household if the household's gross income has decreased by 10% or more.
  • Triennial reexaminations are a potentially strong incentive to encourage increased work and earnings. It would allow more Years to pass before families are required to have their eligibility for their "total tenant payment" (TTP) re-determined a process commonly referred to as "recertification."
  • A change in the recertification timeframe from an annual recertification schedule to a longer recertification period means that no matter how much families earned during that period, none of the increased earnings would go toward higher contributions for rent and utilities (as would be true under traditional rules).
  • An extended recertification period could also reduce the administrative burden: public housing authority (PHA) staff would Spend less time conducting re-certifications, and families would spend less time having to document and report their incomes to the PHA.

Robeson county will amend the public housing admissions and continued occupancy policy (ACOP) and gain board approval by June 30, 2023. The triennial reexaminations will begin with families that have annual recertification due in July 2023. Additional families will be phased in at the time of their annual recertification. RCHA will continue this process until all Current and new families are phased in. This process will take approximately a year (July 1, 2023 -June 30, 2024) to Implement.

Utility reimbursements (PH)
Robeson County housing authority will eliminate utility reimbursement payments in the public housing program when the Utility allowance is greater than the total tenant payment.

MTW goal 2: Give incentives to families with children where the head of household is working; is seeking work; or is preparing for work by participating in job training, educational programs, or programs that assist people to obtain employment and become economically self-sufficient.

Family Self-Sufficiency Program with MTW Flexibility: Modify or Eliminate the Contract of Participation (PH) The Robeson County Housing Authority will modify the terms of the FSS Contract of Participation (HUD-52650), in lieu of a local form. The RCHA will modify the terms of the Contract of Participation to align with adjustments made to its MTW FSS Program using MTW flexibility.

The RCHA will disburse a portion of the FSS escrow account funds before completion of the Contract of Participation (CoP) when the family has met certain interim goals, which means the family has met all its obligations under the CoP to date, Including completion of the Individual Training and Service Plans (ITSP) interim goals and tasks to date, and: Requested funds are needed to complete an interim goal or task within the CoP and are not ongoing expenses.

The RCHA may also use unrestricted net position funding for reasonable and eligible FSS supportive services costs, in amounts approved by the Board of Commissioners in its annual budget process. The PHA may also use its funding flexibility as an MTW agency to utilize Capital Funds for these purposes.

MTW self-sufficiency program: alternative family selection procedures (PH)

BRIDGE Program
RCHA will develop a MTW basic skill set program called BRIDGE for youth and adult residents. RCHA will use incentives to motivate children and teens to become interested in out-of-school time programs that they might not have been interested in Initially. Using incentives can help attract and retain children and youth by promoting program attendance and making young people feel invested in programs.
Some programs that RCHA will implement with youth are Report Card Rewards, A Clean and Green Community Program, Summer Youth Work Program, Tool Time with Teens, Sports Participation Programs, and other programs deemed Appropriate for youth development.
For adults, the program will include skills assessment/job readiness training; health assessment and services referrals; Identified transportation needs, and childcare needs; training in basic financial literacy and credit education; and ready ready-to-rent training. RCHA will make participation in the MTW Self-Sufficiency program mandatory for any household Member that is non-working, non-elderly, or non-disabled.
RCHA will not use income increases during participation in the MTW program to change a family's eligibility status for purposes of participation in the MTW Self-Sufficiency Program or for the receipt of public housing or HCV assistance.

TIDY (Techniques to Improve and Discipline Yourself)
RCHA will Reduce Costs and Achieve Greater Cost-Effectiveness in Federal Expenditures by Streamlining unit inspections for Public Housing residents and offering an incentive for good housekeeping as a way to preserve the housing stock and reduce maintenance costs. In 2022 RCHA moved from conducting annual inspections to biannual inspections and in 2023 will implement the incentive program, a $50.00 incentive for good housekeeping. We will also assist families with becoming more self-sufficient by implementing a program called TIDY. TIDY will teach residents techniques that will help them save money in the home instead of allotting funds to pay maintenance charges for damage and excess utilities. They will also receive tips on how to clean on a budget. The ultimate goal of TIDY is to teach residents how to take care of their homes so they will be self-sufficient once they transition out of public housing.

MTW Goal 3: Increase Housing Choices for Eligible Low-Income Families

Seek Non-Profit Status and Increase Housing Portfolio.
In the 2022 Supplement, RCHA used its flexibility to develop a nonprofit affiliate. In 2023, RCHA will continue to use its flexibility to support the administrative and functional costs of the nonprofit. The nonprofit affiliate will enable the Robeson County Housing Authority to act more like a private housing developer in addressing local needs, provide flexibility to acquire Property on the private market, and give the agency the ability to attract more funding through its nonprofit 501 c3 status.

Acquisition Without Prior HUD Approval.
RCHA will be authorized to acquire public housing sites without prior HUD approval. This activity allows flexibility around the timing of HUDs approval, but the not content of the approval. When acquiring the sites, the RCHA will have all submission materials in place as if HUD were approving the acquisition proposal prior to acquisition. The RCHA will provide the materials to the field office for approval within 30 days of acquisition.

Housing Development Program
RCHA will use MTW funding to acquire, renovate and/or build affordable units for low-income families that are not public Housing units. Eligible activities may include gap financing for non-PHA development of affordable housing, development of project-based voucher units, or tax credit partnerships. The RCHA will incorporate predevelopment costs in its 5-year capital funds plans and utilize these funds for costs associated with the development of non-PHA affordable housing. The following are work items that require funding: site control, appraisals, market analysis, survey, subsurface soil analysis, environmental review, site, and utility engineering, schematic landscape planning, schematic architectural drawings, schematic permits, and fees, legal, accounting, development management and feasibility consulting.

The Policies that the MTW Agency Is Using or Has Used (Currently Implement, Plan to Implement in The Submission Year, Plan to Discontinue, Previously Discontinued).

1. Tenant Rent Policies
c. Stepped rent (PH) - Will Be Discontinued in The Submission Year
m. Utility Reimbursements (PH) - Plan to Implement in The Submission Year

2. Payment Standards and Rent Reasonableness

3. Reexaminations
a. Alternative Reexamination Schedule for Households (PH) - Plan to Implement in The Submission Year

4. Landlord leasing incentives

5. Housing Quality Standards (HQS)

6. Short-Term Assistance

7. Term-Limited Assistance

8. Increase Elderly Age (PH and HCV)

9. Project-Based Voucher Program Flexibilities

10. Family Self-Sufficiency Program with MTW Flexibility
c. PH Alternative Family Selection Procedures (PH) - Currently Implementing
d. PH Modify or Eliminate the Contract of Participation (PH) - Plan to Implement in the Submission Year

11. MTW Self-Sufficiency Program

12. Work Requirement

13. Use of Public Housing as An Incentive for Economic Progress (PH)

14. Moving on Policy

15. Acquisition Without Prior Hud Approval (PH)
Acquisition Without Prior Hud Approval (PH) - Currently Implementing

16. De-concentration of Poverty in Public Housing Policy (PH)

17. Local, Non-Traditional Activities
c. Housing Development Programs - Currently Implementing

C. MTW Activities Plan That Robeson County Plans to Implement in The Submission Year or Is Currently
Implementing

1.M. - Utility Reimbursements (PH)
Describe the MTW activity, the MTW agency's goal(s) for the MTW activity, and, if applicable, how the MTW Activity Contributes to A Larger Initiative

Robeson county housing authority will eliminate utility reimbursements (UR) payments when the utility allowance is greater than the TTP. This will reduce the time and cost associated with cutting checks and mailing them to utility companies. In the future, the RCHA plan to increase the minimum rent, therefore it would reduce the number of families that qualify for UR. This waiver will not result in the agency per-family contribution increasing. However, it will result in about 50 families paying more towards their housing costs because they will no longer receive the reimbursement check to offset those utility costs. There will be no impact on the waiting list. No impact on the termination rate of families. It will not affect the utilization rate. Moreover, it will meet the MTW goal of cost-effectiveness by the agency no longer spending time to issue UR checks. It will also meet the MTW goal of a reasonable rent policy that encourages employment and family self-sufficiency. Lastly, it will not affect protected classes.

What are the cost implications of this MTW activity? Pick the best description of the cost implications based on what you know today.
Increased revenue; Decreased expenditures

Does the MTW activity under this waiver apply to all assisted households or only to a subset of assisted households?
The MTW activity applies to all assisted households.

Based on the fiscal year goals listed in the activity's previous fiscal year's narrative, provide a description about what has been accomplished or changed during the implementation.
A new activity has not previously been implemented.

3.a. - Alternative Reexamination Schedule for Households (PH)
Describe the MTW activity, the MTW agency's goal(s) for the MTW activity, and, if applicable, how the MTW Activity contributes to a larger initiative.
RCHA will reduce the frequency of tenant reexaminations to triennially for all families allowing one interim adjustment per year at the request of the household if the households gross income has decreased by 10% or more.

Triennial Reexaminations are a potentially strong incentive to encourage increased work and earnings. It would allow more years to pass before families are required to have their eligibility for their "total tenant payment" (TTP) redetermined-a process commonly referred to as "recertification."

A change in the recertification timeframe from an annual recertification schedule to a longer recertification period means that no matter how much families earned during that period, none of the increased earnings would go toward higher contributions for rent and utilities (as would be true under traditional rules).

An extended recertification period could also reduce the administrative burden: Public Housing Authority (PHA) staff would spend less time conducting recertifications, and families would spend less time having to document and report their incomes to the PHA.

Robeson County will amend the Public Housing Admissions and Continued Occupancy Policy (ACOP) and gain board approval by June 30, 2023. The Triennial Reexaminations will begin with families that have annual recertification due in July 2023. Additional families will be phased in at the time of their annual recertification. RCHA will continue this process until all current and new families are phased in. This process will take approximately a year (July 1, 2023 -June 30, 2024) to implement.

Which of the MTW statutory objectives does this MTW activity serve?
Cost effectiveness


What are the cost implications of this MTW activity? Pick the best description of the cost implications based on what you know today.
Neutral (no cost implications)


Does the MTW activity under this waiver apply to all assisted households or only to a subset of assisted households?
The MTW activity applies to all assisted households.


Based on the Fiscal Year goals listed in the activity's previous Fiscal Year's narrative, provide a description about what has been accomplished or changed during the implementation.
In 2022, the Robeson County Housing Authority updated its Public Housing Admissions and Continued Occupancy Policy (ACOP) to include triennially recertification in the policy. A 45-day review period and a hearing were conducted for residents and the community. The RCHA board of commissioners approved the changes made to the ACOP. All residents received notice regarding the policy change. Additionally, a plan for implementation has been created internally and staff have been trained. We received the MTW technology grant and are waiting for system improvements to be made so we can track the recertifications electronically. In the alternative, we will create a separate filing system until the system is up and running.


Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described?
No


What is the recertification schedule?
Once every three years


How many interim re-certifications per year may a household request?
1

Please describe briefly how the MTW agency plans to address changes in family/household circumstances under the alternative reexamination schedule.
Households may request one interim recertification per year if they have a 10% or more decrease in total household income. Households at zero income will have an interim certification when new income begins, or after 3 months of zero income, an interim will be completed with income from the previous certification. For households experiencing a hardship beyond these parameters, RCHA will consider classifying it as a long-term hardship. The RCHA Hardship Policy allows the authority the flexibility to address unique, unforeseeable circumstances that may occur and to protect families in crisis. To be considered for a hardship exemption, the household must apply for all benefits for which it may be eligible. Zero-income households must report income changes when income begins. For households experiencing hardship beyond these parameters, RCHA will consider classifying it as a long-term hardship. If RCHA determines there is a long-term hardship the family will be exempt from the MTW activity until the hardship no longer exists.

10.c.PH - Alternative Family Selection Procedures (PH)
Describe the MTW activity, the MTW agency's goal(s) for the MTW activity, and, if applicable, how the MTW activity contributes to a larger initiative.

1. BRIDGE Program
RCHA will develop a MTW basic skill set program called BRIDGE for youth and adult residents. RCHA will use incentives to motivate children and teens to become interested in out-of-school time programs that they might not have been interested in initially. Using incentives can help attract and retain children and youth by promoting program attendance and making young people feel invested in programs. When identifying and using incentives, RCHA will consider the participants' ages, program needs, and potential supporters, and create a strategy to obtain support.
Some programs that RCHA will implement with youth are Report Card Rewards, A Clean and Green Community Program, Summer Youth Work Program, Tool Time with Teens, Sports Participation Programs, and other programs deemed appropriate for youth development.
For adults, the program will include skills assessment/job readiness training; health assessment and services referrals; identified transportation needs, and childcare needs; training in basic financial literacy and credit education; and ready ready-to-rent training. RCHA will make participation in the MTW Self-Sufficiency program mandatory for any household member that is non-working, non-elderly, or non-disabled.
RCHA will not use income increases during participation in the MTW program to change a family's eligibility status for purposes of participation in the MTW Self-Sufficiency Program or for the receipt of public housing or HCV assistance.

2. TIDY (Techniques to Improve and Discipline Yourself)
RCHA will Reduce Costs and Achieve Greater Cost-Effectiveness in Federal Expenditures by Streamlining unit inspections for Public Housing residents and offering an incentive for good housekeeping as a way to preserve the housing stock and reduce maintenance costs. In 2022 RCHA moved from conducting annual inspections to biannual inspections and in 2023 will implement the incentive program, a $50.00 incentive for good housekeeping. We will also assist families with becoming more self-sufficient by implementing a program called T.I.D.Y (Techniques to Improve and Discipline Yourself). TIDY will teach residents techniques that will help them save money in the home instead of allotting funds to pay maintenance charges for damage and excess utilities. They will also receive tips on how to clean on a budget. The ultimate goal of TIDY is to teach residents how to take care of their homes so they will be self-sufficient once they transition out of public housing.

Which of the MTW statutory objectives does this MTW activity serve?
Self-sufficiency

Does the MTW activity under this waiver apply to all assisted households or only to a subset of assisted households?
The MTW activity applies to all assisted households.

Based on the fiscal year goals listed in the activity's previous fiscal year's narrative, provide a description about what has been accomplished or changed during the implementation.
RCHA moved from conducting annual inspections to biannual inspections and in 2023 will implement the incentive program, a $50.00 incentive for good housekeeping. Additionally, RCHA implemented the TIDY (Techniques to Improve and Discipline Yourself) program with residents that failed their initial inspections. The following data shows that 27 Individuals that failed their initial inspections and attended the TIDY class in 2023, passed their second inspection.

RCHA in partnership with Robeson Community College conducted a series of workforce development trainings. There was a total of nine individuals that completed the course. In 2022, RCHA did not make it mandatory for participation. However, in 2023 it will be mandatory for any household member that is non-working, non-elderly, or non-disabled.

RCHA also implemented Report Rewards for youth residents. This program offers incentives for youth that made the A or A/B honor roll per report card period. The program was initiated in January 2023.

Does the MTW agency need a safe harbor waiver to implement this MTW activity as described?
No

Please describe the purpose and goals of the alternative contract or locally developed agreement, and/or the MTW agency's motivation for developing its own contract or agreement.
Robeson County Housing Authority wants to develop its own recruitment and selection procedures for its MTW Self-Sufficiency Program. We currently have the FSS program but would like to target both adults and youth and make participation in the MTW Self-Sufficiency Program mandatory for any household member that is non-elderly or non-disabled. However, any supportive services provided in the Program will be offered to elderly and disabled household members that qualify for such services.

10.d.PH - Modify or Eliminate the Contract of Participation (PH)

Describe the MTW activity, the MTW agency's goal(s) for the MTW activity, and, if applicable, how the MTW Activity contributes to a larger initiative.

Robeson County Housing Authority was awarded the Family Self Sufficiency (FSS) grant on January 26, 2023. Robeson County Housing Authority will implement a Family Self-Sufficiency Program with MTW Flexibility. Below are RCHA MTW Policies which are outlined in the RCHA's FSS action plan:

  • Any adult member of an eligible FSS family may sign the Contact of Participation (CoP) and work to complete the Individualized training and services plan (ITSP), not just the head of household, but there will be only one CoP per family.
  • The CoP will have an initial term of 5 years, and for good cause in the discretion of Robeson County Housing, may be extended between 1 and 5 additional years.
  • If the CoP is ended for any reason other than the participant's failure or refusal, without good cause, to comply with the Terms of the CoP, then the CoP will be considered nullified rather than terminated, and the FSS escrow funds earned to that date will be distributed to the family.
  • If the person who signed the CoP becomes permanently disabled and unable to work or dies during the period of the CoP and it is not possible to modify the CoP to designate a new adult in the FSS family, then the CoP will be nullified, and escrow funds will be distributed to the family.
  • The RCHA will disburse a portion of the FSS escrow account funds before completion of the Contract of Participation (CoP) when the family has met certain interim goals, which means the family has met all its obligations under the CoP to date, including completion of the Individual Training And Service Plans (ITSP) interim goals and tasks to date, and: Requested funds are needed to complete an interim goal or task within the CoP and are not ongoing expenses.
  • Interest earned in Robeson County Housing's combined bank account for FSS escrow funds will be retained for FSS program purposes, including supportive services for FSS participants and training for FSS staff.
  • The RCHA may also use unrestricted net position funding for reasonable and eligible FSS supportive services costs, in amounts approved by the Board of Commissioners in its annual budget process. The PHA may also use its funding flexibility as an MTW agency to utilize Capital Funds for these purposes.

Which of the MTW statutory objectives does this MTW activity serve?
Self-sufficiency

What are the cost implications of this MTW activity? Pick the best description of the cost implications based on what you know today.
Neutral (no cost implications)

Does the MTW activity under this waiver apply to all assisted households or only to a subset or subsets of Assisted households?
The MTW activity applies to all assisted households.

Based on the Fiscal Year goals listed in the activity's previous Fiscal Year's narrative, provide a description about what has been accomplished or changed during the implementation.
A new activity has not previously been implemented.

Does this MTW activity require a hardship policy?
Yes, this document is attached.

Does the hardship policy apply to more than this MTW activity?
Yes

Please list all the applicable MTW activities. (Only upload hardship policy once when said policy applies to multiple MTW activities.)
3.a. - Alternative Reexamination Schedule for Households (PH)

Has the MTW agency modified the hardship policy since the last submission of the MTW supplement?
Yes

What considerations led the MTW agency to modify the hardship policy?
Addition of the new wavier

How many hardship requests have been received associated with this activity in the past year?
No hardship was requested in the most recent fiscal year.

Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described?
No

Does the MTW activity require an impact analysis?
Yes, this document is attached.

Please list all the applicable MTW activities. (Only upload impact analysis once when said impact analysis applies to multiple MTW activities.)
3.a. - Alternative Reexamination Schedule for Households (PH)

15. - Acquisition Without Prior HUD Approval (PH)

Describe the MTW activity, the MTW agency's goal(s) for the MTW activity, and, if applicable, how the MTW activity contributes to a larger initiative.
RCHA will be authorized to acquire public housing sites without prior HUD approval. This activity allows flexibility around the timing of HUDs approval, but the not content of the approval. When acquiring the sites, the RCHA will have all submission materials in place as if HUD were approving the acquisition proposal prior to acquisition. The RCHA will provide the materials to the field office for approval within 30 days of acquisition.

Which of the MTW statutory objectives does this MTW activity serve?
Housing choice

What are the cost implications of this MTW activity? Pick the best description of the cost implications based on what you know today.
Increased revenue

Does the MTW activity under this waiver apply to all assisted households or only to a subset or subset of assisted households?
The MTW activity applies to all assisted households.

Based on the Fiscal Year goals listed in the activity's previous Fiscal year's narrative, provide a description about what has been accomplished or changed during the implementation.
Robeson County Housing Authority is currently in the process of purchasing eight acres of land to use for the first supportive housing development project in Robeson County targeting youth aging out of foster care. This project will potentially be funded by the North Carolina Housing Finance Agency.

Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described?
No

17.c. - Housing Development Programs

Describe the MTW activity, the MTW agency's goal(s) for the MTW activity, and, if applicable, how the MTW Activity contributes to a larger initiative.

  1. Seek Non-Profit status and increase housing portfolio.
    In the 2022 Supplement, RCHA used its flexibility to develop a nonprofit affiliate. In 2023, RCHA will continue to use its Flexibility to support the administrative and functional costs of the nonprofit. The nonprofit affiliate will enable the Robeson County Housing Authority to act more like a private housing developer in addressing local needs, provide flexibility to acquire property on the private market and give the agency the ability to attract more funding through its nonprofit 501 c3 Status.
  2. Housing Development Program
    RCHA will use MTW funding to acquire, renovate and/or build affordable units for low-income families that are not public Housing units. Eligible activities may include gap financing for non-PHA development of affordable housing, development of project-based voucher units, or tax credit partnerships. The RCHA will incorporate predevelopment costs in its 5-year Capital funds plans and utilize these funds for costs associated with the development of non-PHA affordable housing. The following are work items that require funding: site control, appraisals, market analysis, survey, subsurface soil analysis, environmental review, site, and utility engineering, schematic landscape planning, schematic architectural drawings, schematic permits, and fees, legal, accounting, development management and feasibility consulting.

Which of the MTW statutory objectives does this MTW activity serve?
Housing choice

What are the cost implications of this MTW activity? Pick the best description of the cost implications based on what you know today.
Increased revenue; decreased expenditure.

Does the MTW activity under this waiver apply to all assisted households or only to a subset or subset of assisted households?
The MTW activity applies to all assisted households.

Based on the Fiscal Year goals listed in the activity's previous Fiscal Year's narrative, supply a description about what has been accomplished or changed during the implementation.
In the 2022 supplement, RCHA used its flexibility to develop a nonprofit affiliate, Robeson Development Corporation.
Also, Robeson County Housing Authority used its flexibility in funding to aid with the payment of pre-development costs for land that we are acquiring for a supportive housing development project targeting youth aging out of foster care.

Does the MTW agency need a safe harbor waiver to implement this MTW activity as described?
No

Table 17.c.1 - Housing Development Programs That the MTW Agency Plans to Commit Funds to in the Fiscal Year.

Name of Development and Address - The Stream
MTW role: Acquisition, Rehabilitation, New Construction - New Construction
Type of MTW Agency Financing: Gap Financing, Tax credit Partnership, Other - Gap Financing
Number of Affordable Units - 10.00
Total Number of Units - 10.00
Number of Units by Affordability - 80% of AMI - 10.00
Number of Units by Affordability - 50% of AMI - 0.00
Number of Units by Affordability - 30% of AMI - 0.00
Number of Units by Affordability - Other - 0.00

Name of Development and Address - Caton Cove
MTW role: Acquisition, Rehabilitation, New Construction - New Construction
Type of MTW Agency Financing: Gap Financing, Tax credit Partnership, Other - Gap Financing
Number of Affordable Units - 15.00
Total Number of Units - 15.00
Number of Units by Affordability - 80% of AMI - 15.00
Number of Units by Affordability - 50% of AMI - 0.00
Number of Units by Affordability - 30% of AMI - 0.00
Number of Units by Affordability - Other - 0.00

Name of Development and Address - Westgate Terrace
MTW role: Acquisition, Rehabilitation, New Construction - Rehabilitation
Type of MTW Agency Financing: Gap Financing, Tax credit Partnership, Other - Gap Financing
Number of Affordable Units - 100.00
Total Number of Units - 100.00
Number of Units by Affordability - 80% of AMI - 100.00
Number of Units by Affordability - 50% of AMI - 0.00
Number of Units by Affordability - 30% of AMI - 0.00
Number of Units by Affordability - Other - 0.00

Housing Development Programs that the MTW Agency plans to spend Funds on in the Fiscal Year.

Name of Development and Address - Caton Cove
MTW role: Acquisition, Rehabilitation, New Construction - New Construction
Type of MTW Agency Financing: Gap Financing, Tax credit Partnership, Other - Gap Financing
Number of Affordable Units - 15.00
Total Number of Units - 15.00
Number of Units by Affordability - 80% of AMI - 15.00
Number of Units by Affordability - 50% of AMI - 0.00
Number of Units by Affordability - 30% of AMI - 0.00
Number of Units by Affordability - Other - 0.00

Table 17.c.2 - Housing Development Programs that the MTW Agency committed funds to in the prior Fiscal Year.

Name of Development and Address - None
MTW role: Acquisition, Rehabilitation, New Construction
Type of MTW Agency Financing: Gap Financing, Tax credit Partnership, Other
Number of Affordable Units
Total Number of Units
Number of Units by Affordability - 80% of AMI
Number of Units by Affordability - 50% of AMI
Number of Units by Affordability - 30% of AMI
Number of Units by Affordability - Other


Housing Development Programs that the MTW Agency spent funds on in the prior Fiscal Year.

Name of Development and Address - None
MTW role: Acquisition, Rehabilitation, New Construction
Type of MTW Agency Financing: Gap Financing, Tax credit Partnership, Other
Number of Affordable Units Total Number Of units
Number of Units by Affordability - 80% of AMI
Number of Units by Affordability - 50% of AMI
Number of Units by Affordability - 30% of AMI
Number of Units by Affordability - Other

D. Safe Harbor Waivers.

D.1 Will the MTW agency give a request for approval of a Safe Harbor Waiver this year?
No Safe Harbor Waivers are being requested.


E. Agency-Specific Waiver(s).

E.1
Agency-Specific Waiver(s) for HUD approval:
The MTW demonstration program is intended to foster innovation and HUD encourages MTW agencies, in consultation with their residents and stakeholders, to be creative in their approach to solving affordable housing Issues facing their local communities. For this reason, flexibility beyond those supported in Appendix I may be needed. Agency-Specific Waivers may be requested if an MTW agency wishes to implement added Activities, or waive a statutory and/or regulatory requirement not included in Appendix I.

In order to pursue an Agency-Specific Waiver, an MTW agency must include an Agency-Specific Waiver request, an impact analysis, and a hardship policy (as applicable), and respond to all of the mandatory core questions as applicable.

For each agency-specific waiver(s) request, please upload supporting documentation, which includes:

  1. A full Description of the activity, including what the agency is proposing to waive (i.e., statute, regulation, and/or Operations Notice),
  2. How the initiative achieves one or more of the 3 MTW statutory aims,
  3. A Description of which population groups and household types that will be affected by this activity,
  4. Any cost Implications associated with the activity,
  5. An implementation timeline for the initiative,
  6. An impact analysis,
  7. A description of the hardship policy for the initiative, and
  8. A copy of all comments received at the public hearing along with the MTW agency's description of how the comments were considered, as a required Attachment to the MTW Supplement.

Will the MTW agency give a request for approval of an Agency-Specific Waiver this year?
No Agency-Specific Waivers are being asked.

E.2
Agency-Specific Waiver(s) for which HUD Approval has been Received:

Does the MTW agency have any approved Agency-Specific Waivers?
MTW agency does not have approved Agency-Specific Waivers.

F. Public Housing Operating Subsidy Grant Reporting.

F.1
Total Public Housing Operating subsidy amount authorized, disbursed by 9/30, remaining, and deadline for disbursement, by Federal Fiscal Year for each year the PHA is designated an MTW agency.

Federal Fiscal Year (FFY) - 2022
Total Operating Subsidy Authorized Amount - $1,115,617
How Much PHA Disbursed by the 9/30 Reporting Period - $277,265
Remaining Not Yet Disbursed - $204,411
Deadline - 2023-06-30

G. MTW Statutory Requirements.

G.1
75% Very Low Income - Local, Non-Traditional.
Hud will verify compliance with the statutory requirement that at least 75% of the households assisted by the MTW agency are very low-income for MTW public housing units and MTW HCVs through HUD systems. The MTW PHA must provide data for the actual families housed upon admission during the PHA's most recently completed Fiscal Year for its Local, Non-Traditional program households.

Income level - Number of Local, Non-Traditional Households Admitted in the Fiscal Year*
80%-50% Area Median Income - 0
49%-30% Area Median Income - 0
Below 30% Area Median Income - 0
Total Local, Non-Traditional Households - 0

*Local, non-traditional income data must be provided in the MTW Supplement form until such time that it can be submitted in IMS-PIC or other HUD system.

G.2
Establishing Reasonable Rent Policy.

Has the MTW agency established a rent reform policy to encourage employment and self-sufficiency?
Yes

G.3
Substantially the Same (STS) - Local, Non-Traditional.

The total number of unit months that families were housed in a local, non-traditional rental subsidy for the prior full calendar year - 0 # of unit months.

The total number of unit months that families were housed in a local, non-traditional housing development program for the prior full calendar year - 0 # of unit months.

Number of units developed under the local, non-traditional housing development activity that were available for occupancy during the prior full calendar year:

Property Name/Address - None
0/1 BR
2 BR
3 BR
4 BR
5 BR
6+ BR
Total Units
Population Type*
If 'Population Type' is Other
# of Section 504 Accessible (Mobility)**
# of Section 504 Accessible (Hearing/Vision)
Was This Property Made Available for Initial Occupancy During the Prior Full Calendar Year?
What Was the Total Amount of Mtw Funds Invested into the Property?

G.4
Comparable Mix (by Family Size) - Local, Non-Traditional.
To demonstrate compliance with the statutory requirement to continue serving a 'comparable mix" of families by family size to that which would have been served without MTW, the MTW agency will provide the number of families occupying local, non-traditional units by household size for the most recently completed Fiscal Year in the provided table.

Family Size: Occupied Number of Local, Non-Traditional Units by Household Size
1 person
2 people
3 people
4 people
5 people
6+ people
Totals - 0

H. Public Comment
Attached you will find a copy of all the comments received and a description of how the agency analyzed the comments, as well as any decisions made based on those comments.

No additional public hearing was held for an Agency-Specific Waiver and/or Safe Harbor Waiver.

I. Evaluations.

No known evaluations.

Impact Analysis

Activity
1.c
Stepped Rent (PH) RCHA will create a stepped rent model by unit size that increases the family's rent payment on a fixed schedule (Annually-July 1st) in both frequency (once per year) and amount (4% FMR).

  1. Describe the activity's impact on the agency's finances (e.g., how much will the activity cost, any change in the agency's per family contribution).
    We anticipate a decrease in rent collected during the interim phase of each tenant's step plan. In the long-term costs will be offset through improved self-sufficiency, which could lead to the tenant's ability to cover their rent. We foresee more tenants obtaining employment and working longer due to their rent increase being on a fixed schedule in both frequency and amount.
  2. Describe the activity's impact on affordability of housing costs for affected Families (e.g., any change in how much affected families will pay towards their Housing costs).
    We anticipate significant benefits to families as well as increased housing choice and self-sufficiency. The Stepped Rent program will encourage full- and part-time employment options.
  3. Describe the impact on the agency's waitlist(s) (e.g., any change in the amount of time families is on the waitlist).
    None expected. Families may achieve self-sufficiency more quickly than in the past, opening units and reducing wait times.
  4. Describe the impact on the agency's termination rate of families (e.g., any change in the rate at which families non-voluntarily lose assistance from the agency)
    No change expected. Possible reduction in termination rate with more families achieving self-sufficiency.
  5. Describe the impact on the agency's current occupancy level in public housing and utilization rate in the HCV program.
    None expected.
  6. Describe the impact on meeting the MTW statutory goals of cost effectiveness, Self-sufficiency, and/or housing choice.
    We anticipate the activity will provide a positive impact on achieving MTW goals through Cost savings in improved self-sufficiency and housing choice for households. This activity Will improve self-sufficiency and housing choice by supporting tenants in gaining & Mainlining employment which could lead to the tenant's ability to cover their rent and/ or Save for a rental deposit or homebuyer down payment.
  7. Describe the impact on the agency's ability to meet the MTW statutory Requirements.
    We anticipate that this activity will have the most significant impact on households in assisting them in becoming more self-sufficient. The collection of more tenant rents will improve overall program cost effectiveness.
  8. Describe the impact on the rate of hardship requests and the number granted and denied as a result of this activity.
    We anticipate a slight increase in hardship requests and the number granted/denied due to the factors affecting employment.
  9. Across the other factors above, describe the impact on protected classes (and any associated disparate impact).
    None expected because the program will not be mandatory. All residents can participate.

Impact Analysis

Activity

11.a MTW Self-Sufficiency Program Alternative Family Selection Procedures (PH)- Mandatory for eligible families.

  1. Describe the activity's impact on the agency's finances (e.g., how much will the Activity cost, any change in the agency's per family contribution)
    We anticipate some increase in expenses due to offering incentives for participation. Supportive programs will be in-kind, which will be provided by community partners. Programs' costs will be offset through improved self-sufficiency, which could lead to the Tenant's ability to cover their rent.
  2. Describe the activity's impact on affordability of housing costs for affected families (e.g., any change in how much affected families will pay towards their housing costs).
    We anticipate significant benefits to families as well as increased housing choice and self-sufficiency. The self-sufficiency program will encourage full- and part-time employment options.
  3. Describe the impact on the agency's waitlist(s) (e.g., any change in the amount of time families is on the waitlist).
    None expected. Families may achieve self-sufficiency more quickly than in the past, opening units and reducing wait times.
  4. Describe the impact on the agency's termination rate of families (e.g., any change in the rate at which families non-voluntarily lose assistance from the agency).
    No major change expected. A possible increase in termination rate may occur due to the program being mandatory for eligible families. However, our goal is to retain families through supportive programs and our hardship policy.
  5. Describe the impact on the agency's current occupancy level in public housing and utilization rate in the HCV program.
    None expected.
  6. Describe the impact on meeting the mtw statutory goals of cost effectiveness, self-sufficiency, and/or housing choice.
    We anticipate the activity will provide a positive impact on achieving mtw goals through cost savings in improved self-sufficiency and housing choice for households. This activity will improve self-sufficiency and housing choice by providing households with the skills and support for employment which could lead to the tenant's ability to cover their rent and/or save for a rental deposit or homebuyer down payment.
  7. Describe the impact on the agency's ability to meet the MTW statutory requirements.
    We anticipate that this activity will have the most significant impact on households in assisting them in becoming more self-sufficient. The collection of more tenant rents will improve overall program cost effectiveness.
  8. Describe the impact on the rate of hardship requests and the number granted and denied as a result of this activity.
    We anticipate a slight increase in hardship requests and the number granted and denied due to the program being mandatory for qualifying families.
  9. Across the other factors above, describe the impact on protected classes (and any associated disparate impact).
    None expected because the program will not be mandatory for elderly and disabled families and individuals that do not meet the definition of an eligible family at section 23 (n)(3) of the US housing Act pf 1937 and those exempted from the community service requirement under section 12 (C) (2)(A), (B), (D) and (E) of the 1937 Act.

Impact analysis

Activity 3.a. Alternative Reexamination Schedule for Households (PH)

  1. Describe the activity's impact on the agency's finances (e.g., how much will the activity cost, any change in the agency's per family contribution).
    We anticipate some increase in expenses due to annual/inflationary rent increases and no corresponding tenant rent share increases. Process costs will be offset by staff and administrative cost savings.
  2. Describe the activity's impact on affordability of housing costs for affected Families (e.g., any change in how much affected families will pay towards their Housing costs).
    We anticipate significant benefits to families as well as increased housing choice and self-sufficiency. The biennial/triennial certification process will allow households to retain Additional earnings and encourage full- and part-time employment options.
  3. Describe the impact on the agency's waitlist(s) (e.g., any change in the amount of time families is on the waitlist).
    None expected. Families keeping more of their earned income may achieve self-sufficiency more quickly than in the past, opening units and reducing wait times.
  4. Describe the impact on the agency's termination rate of families (e.g., any change in the rate at which families non-voluntarily lose assistance from the agency).
    No change expected. Possible reduction in termination rate with recertification less often and household keeping income increases for that time.
  5. Describe the impact on the agency's current occupancy level in public housing and utilization rate in the HCV program.
    None expected.
  6. Describe the impact on meeting the MTW statutory goals of cost effectiveness, Self-sufficiency, and/or housing choice.
    We anticipate the activity will provide a positive impact on achieving MTW goals through Cost savings in staff time as well as improved self-sufficiency and housing choice for Households. Staff will reallocate the time previously spent on certification to assist in Stabilization activities. This activity will improve self-sufficiency and housing choice by Allowing households to keep more income between certifications leading to the ability to Cover rent or save for a rental deposit or homebuyer down payment.
  7. Describe the impact on the agency's ability to meet the MTW statutory Requirements.
    We anticipate that this activity will have the most significant impact on households in Assisting them in becoming more self-sufficient. The staff time saved through less Frequent certification improves overall program cost effectiveness.
  8. Describe the impact on the rate of hardship requests and the number granted and denied as a result of this activity.
    None expected. This change should be an advantage for all households, and households Can request an interim certification annually.
  9. Across the other factors above, describe the impact on protected classes (and any associated disparate impact).
    None anticipated, should be a positive change for households within the protected classes.

Impact Analysis

Activity
10. Family Self-Sufficiency Program with MTW Flexibility: 10.d. Modify or Eliminate the Contract of Participation (PH)

  1. Describe the activity's impact on the agency's finances (e.g., how much will the activity cost, any change in the agency's per family contribution)
    We anticipate some increase in expenses due to offering incentives for participation. supportive programs will be in-kind, which will be provided by community partners. programs costs will be offset through improved self-sufficiency which could lead to the tenant's ability to cover their rent.
  2. Describe the activity's impact on affordability of housing costs for affected families (e.g., any change in how much affected families will pay towards their housing costs).
    We anticipate significant benefits to families as well as increased housing choice and self-sufficiency. The Self-Sufficiency program will encourage full- and part-time employment options.
  3. Describe the impact on the agency's waitlist(s) (e.g., any change in the amount of time families is on the waitlist).
    None expected. Families may achieve self-sufficiency more quickly than in the past, opening units and reducing wait times.
  4. Describe the impact on the agency's termination rate of families (e.g., any change in the rate at which families non-voluntarily lose assistance from the agency).
    No major change expected. A possible increase in termination rate may occur due to the program being mandatory for eligible families. However, our goal is to retain families through supportive programs and our hardship policy.
  5. Describe the impact on the agency's current occupancy level in public housing and utilization rate in the HCV program.
    None expected.
  6. Describe the impact on meeting the MTW statutory goals of cost effectiveness, self-sufficiency, and/or housing choice.
    We anticipate the activity will provide a positive impact on achieving MTW goals through cost savings in improved self-sufficiency and housing choice for households. This activity will improve self-sufficiency and housing choice by providing households with the skills and support for employment which could lead to the tenant's ability to cover their rent and/or save for a rental deposit or homebuyer down payment.
  7. Describe the impact on the agency's ability to meet the MTW statutory requirements.
    We anticipate that this activity will have the most significant impact on households in assisting them in becoming more self-sufficient. The collection of more tenant rents will improve overall program cost effectiveness.
  8. Describe the impact on the rate of hardship requests and the number granted and denied as a result of this activity.
    We anticipate a slight increase in hardship requests and the number granted and denied due to the program being mandatory for qualifying families.
  9. Across the other factors above, describe the impact on protected classes (and any associated disparate impact).
    None expected because the program will not be mandatory for elderly and disabled families and individuals that do not meet the definition of an eligible family at section 23 (n)(3) of the US housing Act pf 1937 and those exempted from the community service requirement under section 12 (C) (2)(A), (B), (D) and (E) of the 1937 Act

MTW hardship policy

This hardship policy applies to the following MTW activities:

  • Alternative Reexamination Schedule: Biennial and Triennial Certification and Interim Requests.
  • Stepped Rent.
  • MTW Self-Sufficiency Program: Alternative Family Selection Procedures.

Definition of hardship types

  1. A Hardship Exists When:
    The family has lost eligibility for or is awaiting an eligibility determination for a federal, state, local assistance program; the family would be evicted as a result of the imposition of MTW activities; the family has experienced a decrease in income because of changed circumstances, including loss or reduction of employment, death in the family, or reduction in or loss of earnings or other assistance; the family has an increase in expenses because of changed circumstances, such as for medical costs, childcare, transportation, education, or similar items; and such other situations and factors determined by the agency to be appropriate.
  2. No Hardship Exists When:
    RCHA determines there is no qualifying hardship MTW activities will be reinstated, including requiring back payment of minimum rent and other costs or fees to RCHA for the time of suspension.
  3. Temporary Hardship Exists When:
    RCHA determines that there is a qualifying hardship but that it is of a temporary nature. The MTW activity will not be imposed for a period of 90 days from the date of the family's request. At the end of the 90-day period, the MTW activity will be imposed retroactively to the time of suspension. RCHA will offer a reasonable repayment agreement for any minimum rent back payment and any other costs and fees paid by RCHA on the family's behalf during the period of suspension.
  4. Long-Term Hardship Exists When:
    RCHA determines if there is a long-term hardship the family will be exempt from the MTW activity until the hardship no longer exists.

Hardship Policy Overview
The RCHA Hardship Policy allows the authority the flexibility to address unique, unforeseeable circumstances that may occur and to protect families in crisis. To be considered for a hardship exemption, the household must apply for all benefits for which it may be eligible. Zero income households must report income changes when income begins. Until income is restored to the household, households must continue to meet the definitions of hardship types above and meet all of the following criteria:

  • Remain in compliance with all program requirements.
  • Not owe RCHA any money or be current with a re-payment agreement.
  • Continued lack of income has not been through the fault of the household.
  • Have applied for financial resources it may be eligible for but been unsuccessful in securing those.
  • Requested the hardship waiver within the deadline set by RCHA. Households have ten (10) business days from the date of their "Notice of Change" letter in which to request an informal hearing.
  • Have not received hardship relief for the same MTW activity previously.

Triennial Certification and Interim Requests -
The new recertification schedule will be once every three years for residents. Households may request one interim recertification per year if they have a 10% or more decrease in total household income. Households at zero income will have an interim certification when new income begins, or after 3 months of zero income an interim will be completed with income from previous certification. For households experiencing a hardship beyond these parameters, RCHA will consider classifying it as a long-term hardship according to the policies and guidelines above.

Stepped Rent - Stepped Rent

  • Initial Rent: Each household will start out paying rent equal to 30% of their total annual gross income in the prior year, or a minimum rent of $50 (whichever is larger).
  • Annual Stepped Rent Increase: RCHA will establish an annual stepped rent increase by unit size. After year 1, each household's rent will increase by 4% of the FMR (with exceptions for hardships and triennial income reexaminations).
  • Triennial Income Reexaminations: at the triennial income reexamination, the PHA will document household income and any changes in household composition. However, the triennial income reexamination will not affect the household's rent.
  • Hardship Rents: A household will receive a hardship if their rent burden exceeds 40% of their current/anticipated total annual gross income or for other circumstances as determined by the PHA. The hardship rent will equal 30% of the household's current/anticipated total annual gross income. The hardship rent will last for 1 to 12 months (at the PHA's discretion) and can be renewed as needed.

MTW Self-Sufficiency Program: Alternative Family Selection Procedures - RCHA will develop an MTW basic skill set program for self-sufficiency including skills assessment/job readiness training; health assessment and services referrals; identified transportation needs, childcare needs; training in basic financial literacy and credit education; and ready read-to-rent training. RCHA will make participation in the MTW Self-Sufficiency Program mandatory for any household member that is non-elderly or non-disabled. For households experiencing hardship, RCHA will consider classifying it as a hardship according to the policies and guidelines above.

Family Self-Sufficiency Program with MTW Flexibility: Modify or Eliminate the Contract of Participation (PH) - Robeson County Housing Authority was awarded the Family Self-Sufficiency (FSS) grant on January 26, 2023. Robeson County Housing Authority will implement a Family Self-Sufficiency Program with MTW Flexibility. For households experiencing a hardship, RCHA will consider classifying it as a hardship according to the policies and guidelines outlined in the FSS Action Plan.

Requesting A Hardship Exception
The family must formally request a hardship exception by submitting a completed Request for Hardship Exception in written form to RCHA. Forms are available upon request at RCHA's administrative office.

If a family requests a hardship exemption, RCHA will suspend the MTW activity beginning the month following the family's hardship request. The suspension will continue until RCHA can determine whether hardship exists and whether the hardship is of a temporary or long-term nature. During suspension, the family will not be required to participate in relevant MTW activities and support will be adjusted accordingly.

Determination will be made as soon as possible but will not take longer than ten (10) business days. If the request does not meet the hardship standards, MTW activities must resume and RCHA will collect any retroactive rent and other fees, if applicable, through a reasonable repayment agreement.

If the request does meet the hardship standards, RCHA will continue to provide an exemption from the MTW activity at a reasonable level and duration in accordance with Its MTW policies.

Appeals

Families who disagree with the hardship review decision may appeal the determination through RCHA's existing grievance process.

Notification of residents

RCHA will:

  • Notify residents of its hardship policy at intake.
  • Review its hardship policy with residents at recertification.
  • Consider if a resident qualifies for a hardship exemption when assistance is to be terminated due to an MTW activity.

Required Record Keeping.

RCHA will preserve all records of hardship requests, determinations, and appeals for the duration of its MTW participation. RCHA will maintain records to ensure traceability of activities and comply with all applicable regulations. When compliant and reasonable, documentation will be maintained in electronic format. Records will be available for public review and inspection at the agency's administration office during normal business hours and supplied to HUD if requested.

Agency Analysis

Based upon data from the hearings conducted it was Determined that the residents viewed the waivers selected by Robeson County Housing Authority as a benefit to their families. The residents indicated that the activities would help move families towards self-sufficiency, be cost effective for both parties and increase housing choices in Robeson County.