Loading...
sr-032310-1eBoard Meeting: March 23, 2010 Agenda Item: ~ - To: Housing Authority Board Chair and Members From: Andy Agle, Director of Housing and Economic Development Subject: City of Santa Monica Housing Authority Draft Administrative Plan Recommended Action Staff recommends that the Housing Authority Board approve all proposed revisions to the Santa Monica Housing Authority's (SMHA) Draft Administrative Plan and adopt the Draft Administrative Plan. Executive Summary The Administrative Plan (Plan) establishes policies and procedures for operational oversight of the SMHA's rental subsidy programs in a manner consistent with mandated U.S. Department of Housing and Urban Development (HUD) regulations. HUD provides federal funds to the SMHA to administer seven distinct rental assistance programs for approximately 1,300 very-low and low-income households who reside in Santa Monica. While programs are strictly governed by HUD policy and regulations, HUD does permit jurisdictions to tailor discretionary policies that address .local needs to the extent that they do not conflict with HUD regulations. 24 CFR 982.54 requires the SMHA Plan to develop and publish policies that address 24 distinct subjects that provide guidance to program applicants and participants,. as well as members of the public and staff. Background The Administrative Plan is not a strategic or planning document, rather an operations manual of policies and procedures. Its purposes include: ® It informs the Housing Authority Board regarding the policies of the SMHA on all aspects of program operations. ® It serves as a policy and procedures manual for staff to adhere to uniformly and consistently in their daily work. ® It provides a standard by which the participants and the public can determine if program applicants and participants are treated equitably. 1 ® It notifies HUD of the policies the SMHA has adopted in conformity with the regulations. HUD develops regulations and notices to interpret, clarify, and define the laws that Congress enacts. SMHA subsequently develops policies and procedures that are consistent with the regulations and creates the Plan. For example, HUD regulations define that a Section 8 program applicant has a finite period of time during which to locate a unit to lease and that this period is from 60 to no more than 120 days. The Administrative Plan states the circumstances under which SMHA will extend the time period beyond 60 days. HUD also expects the SMHA to revise the Plan as needed to comply with frequent changes in HUD regulations and statutes. Since 2003, when the Plan was last revised and adopted, there have been significant non-discretionary changes that govern the Section 8 program. A summary of policy changes is identified in Attachment B. Discussion The Draft Administrative Plan and its policies reflect and comply with changes in HUD regulations and SMHA operations. The Plan changes are primarily made to reflect mandated federal requirements and are not discretionary. A major formatting change to the Plan embeds the specific Code of Federal Regulations citations within each policy instead of referencing them in an Appendix. This change provides a better understanding of the regulations and how the SMHA applies them. Staff has worked with the Legal Aid Foundation of Los Angeles in the development of the Plan, as Legal Aid serves the same target population as the Housing Authority. The Plan reflects green text for discretionary policies that HUD permits, and since the Plan was made available for public comment, HUD has made non-discretionary regulatory changes and those have been integrated into the Plan to keep it current. The Plan reflects those recent changes in blue text. Public commerits and the relevant responses are included in the Plan. 2 Commission Action The Housing Commission reviewed and discussed the Draft Administrative Plan at its September, November, and December 2009 meetings. At the December 2009 meeting, the Housing Commission approved. the SMHA Draft Administrative Plan and recommended City Council/Housing Authority Board adoption. Public Comment The Draft plan was made available fora 45 day public review period, as required by HUD, from December 23, 2009 to February 8, 2010. The public review period was noticed in the Santa Monica Daily Press. All comments have been reviewed by staff and have been integrated into the public comment section ofthe Draft Plan. Financial Impacts ~ Budget Actions No fiscal or budgetary impacts will result from approval of the Plan. Prepared By: Julie Lansing, Housing Authority Administrator Housing and Attachments: Forwarded to Council: Rod Gould Executive Director A. City of Santa Monica Housing Authority Administrative Draft Plan B. Summary of Policy Changes and Clarifications 3 Additional documentation available in City Clerk's Office.