The WHY and HOW of PBVs (Project-Based Vouchers) Where Do I Start? Dominic Mitchell, Esq., St. Paul PHA Section 8 Programs Manager Al Hester, Housing Policy Director September 24, 2015
SECTION 8 HCV: Subsidies to Private Owners $19 Billion Sec 8 Laws & Rules $34 Million 4600 Units, 1200 Owners 2
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St. Paul Public Housing Agency 4619 Housing Choice Vouchers 515 Project Based Vouchers* 24 developments* 19 with supportive services* 5 general occupancy (*includes 38 supportive housing units under construction, but not yet assisted) PBV program underwent rigorous OIG audit, from 2009 to 2010. 4
Section 8: HCV and PBV HCV: Housing Choice Vouchers Move with the tenant ( TBV ) Administered by PHAs and HRAs Number set by PHA contract with HUD Up to 20% can be designated as PBV PBV: Project - Based Vouchers Stay with the Property Administered by PHAs and HRAs After 1 year, a tenant can move with an HCV ( mobility feature) 5
The Other PBV (a/k/a PBRA, Project-Based Rental Assistance) HUD contracts with property owner Not administered by PHAs and HRAs (except as contract administrator) Tenants who move do not get an HCV PBV and PBRA are RAD Options 6
St. Paul PHA PBV Creation 100 units in 1999, initially responsive to tight rental market, low shopping success rates Mixed income projects; Downtown St. Paul Revitalization; Housing 5000 Later added priorities for Supportive Housing and Ending Homelessness Board raised maximum number of PBVs several times; now 544 (~11%) Long moratorium on new PBV offerings, between 2008 and 2011 7
St Paul PHA s Supportive Housing Portfolio 19 of 24 projects; 327 of 515 units Supportive Service Partners include Catholic Charities, YWCA, PPL, Wilder, and many others Serve a variety of populations, and reach them with needed services Some of projects consist of solely PBV units. 8
PBV Advantages and Disadvantages + Leverages investment + Essential component of most supportive housing + Aids in program administration in a time of shrinking Section 8 administrative funding + Helps raise/maintain utilization when rental housing markets are tight - Front-end tasks are time-consuming - Mobility requirement delays waiting list admissions - Mobility can be frozen when HCVs are over-utilized 9
PBV Requires a Team PHA/HRA Board and Staff Housing Owner and/or Developer Housing Manager Funders (Site selection neighbors, community organizations) 10
Supportive Housing PBV Requires a BIGGER Team PHA/HRA Board and Staff Housing Owner and/or Developer Housing Manager Service Provider(s) Funders Site selection neighbors, community organizations Consultants/Technical support (like CSH) 11
PHA/HRA Tasks in PBV Program Creation 1. Design the program 2. Select projects from proposals submitted 3. Get HUD approval 4. Sign AHAP and HAP 5. Administer the program 12
It is PHA/HRA s Choice Policy Decisions by PHA/HRA Board: How many PBV to offer? 20% Limit on using TBV for PBV Selection criteria? Adopt policies in Administrative Plan 13
PHA/HRA Tasks: 1. Design the Program Set program goals Set policies for program operation Decide number/frequency of PBV offerings Establish selection criteria Determine type of public selection process MN Housing SuperRFP or other 24 CFR Sec. 983.51 Notify HUD before issuing RFP 14
PHA/HRA Tasks: 2. Select the Project(s) from Proposals Submitted Controlled by HUD regulations Public selection process required Limited to 25% of units in a property UNLESS for supportive housing, or housing for elderly, or persons with disabilities. 15
Future of PBV Offerings? Interactions with market conditions Volatile Housing Assistance Funding Volatile Administrative Fee Funding Supportive Service PBV? Reaching diverse, homeless populations with needed supportive services. Importance of Partnership and Collaboration Mixed income projects Choice, Fair Housing issues 16
3. Get HUD Approval Environmental Review Subsidy Layering Review (By HUD or MN Housing) Narrative description of project includes Selection process Target population (Fair Housing issues) Compliance with site and neighborhood standards Accessibility Rent Levels (Reasonable) 17
4. AHAP and HAP Once HUD approves PBV Project, sign AHAP ( Agreement to Enter into a Housing Assistance Payments Contract ) See HUD Forms for PBV AHAP and HAP No construction or rehab until AHAP is signed Davis Bacon and Section 3 apply All PBV units in the project must pass HQS inspection before HAP signing. SAVE THE INSPECTION BOOKS! 18
4. AHAP and HAP, cont d HAP Contract must be signed before subsidies start PHA discretion in HAP contract: Vacancy losses: PHA can strike that section HAP contract specifies which units are included Units can be removed from HAP contract later if longvacant or zero-hap Units can be added back to contract after removal for zero-hap (HERA) 19
5. Administer the Program St. Paul PHA allows Supportive Service Projects to refer their own tenants. Tenant Screening Owner screens for tenant suitability Service provider screens for program requirements PHA/HRA determines Section 8 eligibility Mobility Avoid over- and under-housing 20
Applicant Eligibility PBV serves very low income and extremely low income families Citizenship/legal immigration status required Criminal background checks Previous PHA Program History Must allow verification of income and household composition Must provide SSN for all HH members 21
Program Administration: Supportive Service Mandate Controversial Regulations allow a supportive housing project to have over 25% of units with PBVs, but clients must participate in supportive services. 24 CFR Sec. 983.56 requires the PHA to monitor this. (OIG, too) Supportive Housing advocates don t favor mandatory services. 22
Program Administration: Right to Move ( Mobility ) Housing Choice Voucher after 12 months, IF PHA/HRA is issuing any new vouchers. Tenant Right to Move comes from statute, codified in regulation. Is this a good fit for Supportive Service Projects? 2 for 1 23
Where to get answers? Code of Federal Regulations: 24 CFR Part 983 on www.fdsys.gov HUD Notice PIH 2015-05 Corporation for Supportive Housing www.csh.org 612-721-3700 Minnesota Housing [MHFA] www.mnhousing.gov 651-296-7608 24
Agency Contact Information Saint Paul Public Housing Agency www.stpha.org 651-298-5664 Dominic Mitchell, Section 8 Programs Manager dominic.mitchell@stpha.org; 651-292-6191 Al Hester, Housing Policy Director al.hester@stpha.org; 651-292-6173 25