TBRA Recertifications, Revisions, Preliminary Review

Transcription

1 HOME Investments Partnership Program Tenant Based Rental Assistance (TBRA) Recap of 2012 Rules Changes for TBRA Recertifications Interim Revisions Preliminary Review Option Administered by

2 TBRA Recertifications, Revisions, Preliminary Review This webinar presentation addresses: Brief recap of changes to 2012 HOME Rules affecting TBRA Overview of Recertification and interim revision requirements New procedures required for submitting Recertification and interim revision documents using the Recertification module in the online Housing Contract System (HCS) New option for Preliminary Review and approval of project setups Recommended best practices for TBRA administration 2

3 Recap of 2012 Rules Changes Affecting TBRA 3

4 Recap of 2012 Rules Changes Affecting TBRA 2012 HOME Rules at 10 TAC 23 include several changes affecting administration of the TBRA Program 10 TAC 23 is available online at: 4

5 Interim Revisions 2012 Rules no longer require interim revisions for households whose income changed more than $200 per month Example: ABC Organization s Administrative Plan (i.e. Program Design) specifies a requirement for interim revisions only when household income decreases $100 or more per month. It does not require interim revisions for household income increases. Scenario #1: Mr. Tenant received a raise of $210 per month and reported his increased income to ABC Organization. ABC Organization is not required to submit an interim revision for income increases. ABC Organization retains the information in Mr. Tenant s file, but is not required to revise the TBRA subsidy amount until the annual 12 month anniversary date. Scenario #2: Mrs. Renter lost her job and her household income decreased by $1,000 month. ABC Organization s Administrative Plan (Program Design) requires interim revisions for income decreases of $100 or more per month. ABC Organization submits an interim revision adjusting Mrs. Renter s monthly subsidy amount. Mrs. Renter s 12 month annual recertification must be completed on or before her original anniversary date. 5

6 Minimum /Maximum Tenant Payment To comply with HUD requirements, 2012 Rules now specify that the Total Tenant Payment (TTP) contribution toward rent: Must be at least 10% of the household s gross monthly income; and Cannot exceed 40% of the household s adjusted monthly income at initial occupancy TTP worksheet now includes this calculation 6

7 Extended Term of Assistance 60 Months Lifetime Limit Under 2012 Rules, TBRA assistance may extend up to a 60 month lifetime limit Initial setup amount to a household cannot exceed 24 months At the end of 24 months, an additional 12 month extension is available under a subsequent Contract/Reservation award Subsequent extensions up the 60 month lifetime limit per household may be approved if the following requirements are met: Tenant must apply for a Section 8 Housing Choice Voucher (HCV) and be on a Section 8 wait list; and Tenant must not have been removed from a Section 8 HCV wait list due to failure to respond or other ineligibility factors; and Tenant must not have been denied participation in Section 8 HCV program while being assisted with TBRA; and Tenant must not have refused to participate in Section 8 HCV program when a voucher was available Section 8 wait list status must be documented 7

8 Lease Start Date Must Agree with Rental Coupon Contract Per 2012 Rules, the lease start date and the Rental Coupon Contract (RCC) start date must be the same date. Example: Mr. Applicant has an existing lease with Sunshine Apartments which started 5 months ago. He is approved for TBRA and receives an RCC with start date of. Mr. Applicant must obtain a new lease with Sunshine Apartments that has a lease start date of July 31, 2013, and provide a copy of that new lease to Administrator. 8

9 Recertifications and Interim Revisions Procedural Overview 9

10 Recertification of Household Eligibility To continue providing TBRA assistance to an assisted household, Administrator must recertify the household s eligibility on or before the 12 month anniversary date of assistance by reverifying : Income eligibility Obtain new support documentation Complete a new Household Income Certification (HIC) Complete a new Total Tenant Payment (TTP) Worksheet Unit eligibility Conduct visual unit inspection Complete and sign/date Housing Quality Standards (HQS) Form Remaining period of eligibility Potential 60 month lifetime limit 10

11 Recertification of Household Eligibility (continued) Best practice: Begin the recertification process days prior to the household s anniversary date in order to allow sufficient time to: Collect and review new support documentation Issue and execute new forms, as required Inspect the rental unit and allow time for completion of repairs and reinspection (if needed) 11

12 Recertification Assisted Household Procedures Assisted household must: Complete a new Intake Application form available online at: division/forms/home_forms_tbra.htm Report changes in household composition Report changes in income and assets, including but not limited to: Employment SS, SSI, SSDI, and VA benefits Child support Checking and savings accounts Retirement accounts Report changes to expenses, including: Child care Medical and Disability related expenses Provide new support documents verifying income and assets Sign new forms and documents as requested 12

13 Recertification Administrator Procedures Administrator must: Review new support documents for completeness and accuracy Obtain 3 rd party verification of income and assets Verify the assisted household continues to meet Program eligibility requirements Conduct a physical inspection of the rental unit to verify compliance with HQS Obtain executed forms and documents, as applicable Compile.pdf Recertification Packet Update the HCS online project status to Pending Recertification Attach Recertification Packet to HCS 13

14 Income Eligibility At the time of recertification, the assisted household must continue to have annual gross income at or below 80% of Area Median Family Income (AMFI). Any income restrictions included in the TBRA Contract or Reservation Agreement only apply at initial occupancy 14

15 Unit Eligibility Administrator must conduct a physical inspection of the rental unit: Must be completed annually on or before the assisted household s 12 month anniversary date Prepare a signed/dated HQS Form available online at: division/forms/home_forms_tbra.htm Rent reasonableness guidelines apply at recertification: Ensure the rent for the unit is at or below the Fair Market Rent (FMR) for the area Best Practice: The annual inspection should occur days prior to the recertification date to allow sufficient time for reinspection if necessary. 15

16 Recertification Packet Compile the.pdf Recertification Packet: Intake Application with Addendum New Rental Coupon Contract (RCC) New lease agreement 2012 Rules: Lease start date must be same as new RCC start date HQS Form dated on or before anniversary date HIC TTP Worksheet Support documentation verifying continued eligibility Update the HCS to Recert Submitted status Attach the complete Recertification Packet to HCS ed Recertification documents will not be accepted Best Practice: Submit Recertification Packets 30 days prior to the anniversary date 16

17 Interim Revisions Administrative Plan Administrator must establish written policies in its Administrative Plan (Program Design) for processing interim revisions. Household income 2010 Rules: Interim revisions are required when the household income increases by more than $200 per month 2012 Rules: Interim revisions are no longer required for households whose monthly gross income changes by more than $200 per month Best Practice: Interim revisions for income changes should be processed only if your Administrative Plan requires them. 17

18 Interim Revisions Administrative Plan (continued) Unit changes during the rental coupon term If unit changes are permitted: Identify the process for requesting a change Interim revision is always required when the household moves to a new unit prior to annual Recertification Always requires a new HQS inspection If unit changes are not permitted: Identify any extenuating circumstances in which a change would be considered (e.g.: accessibility needs) 18

19 Processing Interim Revisions Interim revisions do not change the date of the annual Recertification Interim revisions do not require re examination of every eligibility factor Only examine the eligibility factor that prompted the need for revision Example: If the assisted household requests to move to a new unit, the interim revision would not require re examination of household income Compile the.pdf Revision Packet: Support documents verifying the applicable change factor Update the HCS to Recert Submitted status Attach the complete Revision Packet to HCS ed Revision documents will not be accepted Best Practice: a revision notification to your Performance Specialist, but do not revision docs 19

20 HCS Recertification Module 20

21 HCS Recertification Module Recent updates to the online Housing Contract System (HCS) now permit Administrator to adjust the status of a project in order to: Notify Performance Specialist that a project s recertification or revision documents are ready for review Attach recertification/revision documents Administrators must attach recertification documents to HCS Please do not recertification documents 21

22 Status Types Each TBRA household setup now has two status types: Project Status Affects funding Cannot be changed by Administrator after initial submittal of setup Recert Status Does not affect funding Allows Administrator to attach documents to HCS Notifies Performance Specialist the project is ready for recertification or revision review At initial setup Project Status is Active and Recert Status is No Recert 22

23 Changing the Recert Status Pending Recert Administrator may change Recert Status to Pending Recert at any time Click Recert Status 23

24 Changing the Recert Status Pending Recert (continued) Select Pending Recert Click Add 24

25 Changing the Recert Status Pending Recert (continued) Status updates to Pending Recert Administrator may now attach documents to HCS 25

26 Attach Documents Attach recertification/revision documents to the project screen 26

27 Changing the Recert Status Recert Submitted After documents have been attached, change status to Recert Submitted Recert Submitted status notifies Performance Specialist to review your attached recertification/revision documents Select Recert Submitted Click Add 27

28 Changing the Recert Status Recert Submitted (continued) Status updates to Recert Submitted 28

29 Performance Specialist Reviews Recert/Revision Packet No Deficiencies: Performance Specialist will: Change status to Recert Complete; and Authorize updates to Project data and/or funding as appropriate Deficiencies: Performance Specialist will: Change status back to Pending Recert Administrator regarding deficiencies Attach deficiency notice to HCS Administrator must: Attach curative documents Again change Recert Status to Recert Submitted 29

30 Preliminary Review Option for Project Setups

31 Two Project Setup Options TDHCA now offers two options for submitting TBRA project setup requests: Traditional Setup complete project setup information and documentation verifying household and unit qualification is submitted all at once Preliminary Review permits partial submittal of project setup information and documents in two separate processes to determine (1) household qualification, and then (2) unit qualification The revised Project Setup Checklist includes instructions for both setup options: division/forms/home_forms_tbra.htm 31

32 Preliminary Review Option The Preliminary Review option has been developed to: Provide TDHCA verification of a household s eligibility prior to the tenant s selection of a unit Provide helpful information to the household regarding how much unit it can afford prior to beginning the search for a housing unit Reduce the occurrence of households entering into a legally binding lease agreement before they have been verified eligible and/or before they know the amount of assistance they may receive Reduce revisions/corrections to required documentation 32

33 Preliminary Review Household Qualification Step #1: Administrator creates the project setup in HCS Since no address will be available at this time, enter TBD as a placeholder address, and use the zip code of the county in which the tenant will reside This action temporarily reserves funds for the project until unit qualification is completed and the project is approved Attach the.pdf Household Approval Packet, which includes: Copy of environmental clearance Intake Application, Intake Addendum, and Intake Supplement HIC TBRA Subsidy Estimate worksheet (included in the HIC workbook) Utility allowance schedule (estimate based on subsidy standard) Income and asset support documentation Verification of disability, if applicable Section 8 Wait List verification (applies only if the household has already been assisted for 36 months) 33

34 Preliminary Review Household Qualification (continued) Step #2: TDHCA determines household eligibility Performance Specialist will review the Household Approval Packet to determine eligibility. If eligible, the Maximum Estimated Subsidy amount will be calculated as follows: Permitted Number of Months Assistance x Maximum Monthly Subsidy from TBRA Subsidy Estimate worksheet = Rental Subsidy + Estimated Maximum Security Deposit (FMR for approved unit size x 2) + $300 (flat rate for estimated Utility Deposit) = MAXIMUM ESTIMATED SUBSIDY Performance Specialist prepares Household Commitment Contract (HCC) based on the Maximum Estimated Subsidy, attaches the HCC to HCS, and places the project into Pending Executed Document status 34

35 Preliminary Review Household Qualification (continued) Step #3: Administrator issues documents to household Certificate of Eligibility Request for Unit Approval How Much Rent Can I Afford (printed from HIC workbook) Notification not to enter into a binding lease agreement prior to unit inspection by Administrator Household selects an affordable housing unit Household has 60 days from date of issuance of the Certificate of Eligibility to select a rental unit May be extended by Administrator for good reason Must notify Administrator and request inspection of selected unit 35

36 Preliminary Review Unit Qualification Step #4: Administrator verifies unit eligibility and submits required documentation Unit inspector must complete and sign/date HQS Form After the unit has been approved by the Administrator, required documents must be executed by Household, Administrator and Landlord, as applicable: Lease and Lease Addendum Rental Coupon Contract (RCC) Attach the.pdf Unit Approval Packet, which includes: HCC executed by Administrator s executor TTP worksheet (included in HIC workbook) RCC Lease and Lease Addendum Utility deposit documentation, if applicable HQS Form

37 Preliminary Review Unit Qualification (continued) Step #5: TDHCA reviews the Unit Approval Packet When the unit has been determined eligible, the Performance Specialist will: Enter the correct project address into the HCS Attach the fully executed HCC Approve the project setup Note: The amount of funds shown on the HCC will often exceed, but should never be less than, the actual subsidy provided to the household 37

38 Recap of Today s Webinar 2012 HOME Rules include changes affecting the administration of the TBRA Program Recertifications must be conducted annually Revisions must be conducted in accordance with the written Administrative Plan (Program Design) Use the new Recertification Module HCS to update the project status and attach Recertification and/or Revision documents TDHCA now offers two options for submitting the initial project setup Traditional setup submit complete documentation Preliminary review permits submittal of partial documentation in two separate processes Household Qualifications Unit Qualifications 38

39 HOME Program Contact Information Questions? Contact your Performance Specialist: Abby Versyp, Team Lead Kay Fairbanks Terry Newman Frances Acosta Sylvia Smith Rita Bunton Jackie Welsh Suzanne Hemphill Thank you for participating in today s webinar! 39