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SR-04-10-2012-9AIs Housing Authority Board City of Santa � 5 Monica' eport City Council Meeting: April 10, 2012 Agenda Item: q- A To: Housing Authority Board Chair and Members From: Andy Agle, Director of Housing and Economic Development Subject: Public Hearing On Housing Authority Annual and Administrative Plans Recommended Action Staff recommends that the Board: 1) Hold a public hearing to receive public comment; 2) Adopt the Housing Authority's FY 2012 -2013 Annual Plan, which includes revisions to the Administrative Plan; and 3) Authorize the Executive Director to submit the Plans to the United States Department of Housing and Urban Development (HUD). Executive Summary The Santa Monica Housing Authority (SMHA) is required to submit an Annual Plan that describes policy direction and discretionary policy changes to the Administrative Plan. The Administrative Plan, a supporting document to the Annual Plan, describes the discretionary policies and operations. HUD's direction under 24 CFR 982.54, requires the SMHA to make policy choices that provide guidance to staff and consistency to program applicants and participants. This report presents the Plans and summarizes proposed discretionary changes. Background SMHA currently administers approximately 1,200 federally funded rental vouchers to very -low and low- income households under a contract with the U.S. Department of Housing and Urban Development (HUD). The SMHA must ensure compliance with federal laws, regulations, and notices, as well as establish policies and procedures that clarify federal requirements to ensure consistency in program operations. The Annual and Administrative Plans must include regulatory, statutory, and discretionary changes 1 made since the previous submissions to HUD. The majority of the proposed plan changes are regulatory. ® The 2012 -13 Annual Plan describes the Housing Authority's mission, goals, and objectives, changes to eligibility, selection and admissions policies, and waitlist procedures that govern the administration of the Section 8 Housing Choice Voucher program and other programs administered by the Housing Authority. It requires a statement of financial resources and a fiscal audit. ® The 2012 -13 Administrative Plan describes how the SMHA will implement the activities described in the Annual Plan. It serves as a policy manual for staff to utilize in their daily work to help ensure consistency. It also provides the standard by which applicants and participants and the broader community can determine equity and transparency. Additionally, it notifies HUD of the policies the SMHA has adopted to conform to regulations. The Annual and Administrative Plans were last adopted by the Housing Authority Board on March 22, 2011 and the Five -Year Plan was adopted by the Housing Authority Board on April 14, 2009. The final Plans must be submitted to HUD for approval by April 17, 2012. Discussion The majority of changes are regulatory and the proposed discretionary changes would modify the Plans to include: 1. Establishment of a Master List tier preference allowing the Housing Authority to transfer a maximum of five Shelter Plus Care (S +C) participants, who are now able to live independently, to the Section 8 program, if vouchers become available. The proposed changes would allow the Housing Authority to provide new S +C vouchers to homeless individuals in need of services and housing. 2. Introduction of a medical claim form to be completed by participants in advance of the reexamination process. The proposed change is expected to streamline procedures to verify medical expenses and calculate income.. 3. Establishment of a minimum rent payment of $50.00 per month by Section 8 participants. The proposed change would ensure that every household makes some contribution toward rent, even if it is very small. 2 4. Establishment of a standard procedure to provide studio -unit vouchers to single - person households with live -in aids, unless a reasonable accommodation has been granted. The proposed change would stretch limited funding to provide more vouchers and accommodate voucher - holders with special needs. Public Outreach A public notice published in the Santa Monica Daily Press on November 25, 2011, provided information on the Plan adoption process, including the Housing Authority Board meeting and where to access draft Plans available for public review. SMHA staff solicited feedback from the Disabilities Commission staff liaison and presented to the Social Services Commissions, Commission for the Senior Community, Commission on the Status of Women, and the Social Services Commission. Staff has also coordinated with the Legal Aid Foundation of Los Angeles (LAFLA). The 45 -day required comment period ended on January 9, 2012. Public comments received during the period have been reviewed by staff and incorporated into the final Plan. The comments received during the 45 -day period were submitted by the Commission for the Senior Community, the Westside Center for Independent Living and one member of the public. HUD requires that the authorities consider all input and respond to it in the Plan, but does not require that all suggestions be recommended. HUD requires that a public hearing be conducted. Commission Action The Housing Commission discussed the Plans at their meetings on November 17, 2011 and February 16, 2012 and passed a motion to recommend that Council adopt the Plans and submit them to HUD for approval. 3 Financial Impacts & Budget Actions Adoption of the Annual and Administrative Plans has no financial or budgetary impact. Failure to adopt the Plans could negatively impact all of Santa Monica's HUD - funded programs. Operational costs to administer the program are covered by HUD and are based on the number of vouchers utilized each month, as defined by HUD formula. Prepared by: Barbara Collins, Housing Manager roved: Andy Agle, Director � Housing and Economic Development Forwarded to Council: Rod Gould s� City Manager Attachments: A. Draft HUD Form 50075 Annual Plan for FY 2012 -13 B. Draft FY 2011 -12 SMHA Administrative Plan C. Spreadsheet of changes made in the FY 2012 -13 Administrative Plan from the FY 2011 -12 adopted Plan D. Spreadsheet of public comments and the SMHA response PHA 5 -Year and U.S. Department of Housing and Urban OMB No. 2577 -0226 Development Expires 4/30/2011 Annual Plan Office of Public and Indian Housing 1.0 PHA Information PHA Name: C'h of Santa Monica Ilousine Authority PHA Code: CAI 11 PHA Type: ❑ Small ® High Performing ❑ Standard ® HCV (Section 8) PHA Fiscal Year Beginning: (MM/YYYY): 07/2012 2.0 Inventory (based on ACC units at time of FY beginning in 1.0 above) Number of Pit units: 0 Number of HCV units: 1.092 310 Submission Type ❑ 5 -Year and Annual Plan ® Annual Plan Only ❑ 5 -Year Plan Only 4.0 PHA Consortia ❑ PHA Consortia: (Check box if submitting ajoint Plan and complete table below.) No, of Units in Hach PHA Program(s) Included in the Programs Not in the program Participating PHAs Code Consortia Consortia piI HCV PHA L PHA 2: PHA 3: 5.0 5 -Year Plan. Complete items 5.1 and 5.2 only at 5 -Year Plan update. 5.1 Mission. State the PIIA's Mission for serving the needs of low- income, very low- income, and extremely low income families in the PI1A's jurisdiction for the next five years: 5.2 Goals and Objectives. Identify the PHA's quantifiable goals and objectives that will enable the P11A to serve the needs of low- income and very low- income, and extremely low- income families for the next five years. Include a report on the progress the PHA has made in meeting the goals and objectives described in the previous 5 -Year Plan, Page 1 oft form HUD -50075 (4/2008) 9.1 Strategy for Addressing Housing Needs. Provide a brief description of the PHA's strategy for addressing the housing needs of families in the jurisdiction and on the waiting list in the upcoming year. Note: Small, Section 8 only, and High Performing PHAs complete only for Annual Plan submission with the 5 -Year Plan. Page 2 of 2 form HUD -50075 (4/2008) PHA Plan Update (a) Identify all PHA Plan elements that have been revised by the PHA since its last Annual Plan submission: 1. Eligibility. Selection and Admissions Policies including Decoucentration and Wait List Procedures: Proposed changes to HCV Administrative Plan: Chapter 3— Eligibility Pages 3 -2, 3 -6 through 3 -8— Clarifies policy regarding adding new family members to household, decreased number of days a guest can remain in assisted units, revised verification policy for children placed in foster care, and clarified certification policy for Live -In Aide Agreement. These revisions are included as an attachment to this Plan. Chnoter 4 — Applications, Waiting List and Tenant Selection Pages 4 -2, 4 -4, 4 -5, 4 -10, 4 -12 — Amended policy to reflect PHA will accept applications by telephone as a reasonable accommodation, updated text to reflect Shelter Plus Care Wait List will be merged with Master Wait List, updated text to reflect PHA may close waiting list upon receipt of a sufficient number of applications, revised Wait List preferences to reflect the assignment of a priority for Shelter Plus Care program participants transitioning to HCV. Clarified text to reflect PHA may interview non -adult family members for eligibility determinations. These revisions are included as an attachment to this Plan. 6.0 2. Financial Resources: A statement of financial resources may be viewed from the City's website: wwwOI.smgov.net/finance/budget/index.htm 3. Rent Determination: Pages 6.32, 6- 34— Revised Minimum Rent Policy to increase minimum amount a family pays for rent and utilities from $25 to $50 per month. These revisions are included as an attachment to this Plan. 11. Fiscal Year Audit: The Audit for fiscal year 2009 -10 is being finalized. (b) Identify the specific location(s) where the public may obtain copies of the 5 -Year and Annual PHA Plan. For a complete list of PHA Plan elements, see Section 6.0 of the instructions. Copies of all documents may be viewed and obtained at the Housing Authority's Administrative Offices located at 1901 Main Street, 0 Floor, Santa Monica, CA 90405. Additionally, the Plans may be downloaded from the Agency's website: little wwwO I singov.net/housing /sectiot18.htrn All items required for public review under 24 CFR 903.7 are available upon request, and can be obtained at: Administrative Offices: 1901 Main Street, V Floor, Santa Monica, CA 90405 7.0 Hope VI, Mixed Finance Modernization or Development, Demolition and /m' Disposition, Conversion of Public Housing, Homeownership Programs, and Project -based Vouchers. Include statements related to these programs as applicable. 8.0 Capital Improvements, Please complete Parts 8.1 through 8.3, as applicable. 8.1 Capital Fund Program Annual Statement /Performance and Evaluation Repot. As part of the PHA 5 -Year and Annual Plan, annually complete and submit the Capital Fund Program Annual StalenrenO'erfo-nrance. and Evalualion Report, form HUD - 50075.1, for each current and open CFP grant and CFFP financing. 8.2 Capital part of the complete sear land Pro Five- Year form HUDP50075.2s, and subsequent annual updates arollio basis, e.g, drop current adda latest year 8 9 P ( g &, P Y Y for a five year period). Large capital items must be included in the Five -Year Action Plan. 8.3 Capital Fund Financing Program (CFFP). ❑ Check if the PHA proposes to use any portion of its Capital Fund Program (CFP) /Replacement Housing Factor (RHF) to repay debt incurred to finance capital improvements. 9.0 Housing Needs. Based on information provided by the applicable Consolidated Plan, information provided by HUD, and other generally available data, make a reasonable effort to identify the housing needs of the low- income, very low- income, and extremely low- income families who reside in thejurisdiction served by the PHA, including elderly families, families with disabilities, and households of various races and ethnic groups, and other families who are on the public housing and Section 8 tenant -based assistance waiting lists. The identification of housing needs must address issues of affordability, supply, quality, accessibility, size of units, and location. 9.1 Strategy for Addressing Housing Needs. Provide a brief description of the PHA's strategy for addressing the housing needs of families in the jurisdiction and on the waiting list in the upcoming year. Note: Small, Section 8 only, and High Performing PHAs complete only for Annual Plan submission with the 5 -Year Plan. Page 2 of 2 form HUD -50075 (4/2008) 10.0 Additional Information. Describe the following, as well as any additional information HUD has requested. (a) Progress in Meeting Mission and Goals. Provide a brief statement of the PHA's progress in meeting the mission and goals described in the 5 -', Year Plan. (b) Significant Amendment and Substantial Deviation/Modification. Provide the PHA's definition of "significant amendment" and "substantial deviation/modification" Required Submission for HUD Field Office Review. In addition to the PHA Plan template (HUD - 50075), PHAs must submit the following documents. Items (a) through (g) may be submitted with signature by mail or electronically with scanned signatures, but electronic submission is encouraged. Items (h) through (i) must be attached electronically with the PHA Plan. Note. Faxed copies of these documents will not be accepted by the Field Office. (a) Form HUD - 50077, P11A Ceritfications of Compliance with the PHA Plans and Related Regulations (which includes all certifications relating to Civil Rights) _ (b) Form HUD - 50070, Certification fora Drug -Free Workplace (PHAs receiving CFP grants only) (c) Form HUD- 50071, Certification of Payments to influence Federal Transactions (PHAs receiving CFP grants only) (d) Form SF- I.I,L, Disclosure of Lobbying Activities (PHAs receiving CFP grants only) (e) Fonn SF- LLL -A, Disclosure of Lobbying Activities Continuation Sheer (PHAs receiving CFP grants only) (I) Resident Advisory Board (RAB) comments. Comments received from the RAB must be submitted by the PHA as an attachment to the PHA Plan. PHAs must also include a narrative describing their analysis of the recommendations and the decisions made on these recommendations. (g) Challenged Elements (h) Form HUD - 50075.1, Capital Fund Program Annual Statement /Performance and Evalualion Report (PHAs receiving CFP grants only) (i) Form HUD- 50075.2, Capital Find Program Five -Year Action Plan (PHAs receiving CFP grants only) Page 3 of 2 form HUD -50075 (4/2008) This information collection is authorized by Section 511 of the Quality Housing and Work Responsibility Act, which added anew section 5A to the U.S. Housing Act of 1937, as amended, which introduced 5 -Year and Annual PHA Plans. The 5 -Year and Annual PHA plans provide a ready source for interested parties to locate basic PHA policies, rules, and requirements conceming the PHA's operations, programs, and services, and informs HUD, families served by the PT 1A, and members of the public of the PHA's mission and strategies for serving the needs of low- income and very low- income families. This form is to be used by all PHA types for submission of the 5 -Year and Annual Plans to HUD. Public reporting burden for this information collection is estimated to average 12.68 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. HUD may not collect this information, and respondents are not required to complete this form, unless it displays a currently valid OMB Control Number. Privacy Act Notice. T'he United States Department of Housing and Urban Development is authorized to solicit the information requested in this form by virtue of Title 12, U.S. Code, Section 1701 cu sec., and regulations promulgated thereunder at Title 12, Code of Federal Regulations. Responses to the collection of information are required to obtain a benefit or to retain a benefit. The information requested does not lend itself to confidentiality Instructions form HUD -50075 Applicability. This form is to be used by all Public Housing Agencies (PHAs) with Fiscal Year beginning April 1, 2008 for the submission of their 5 -Year and Annual Plan in accordance with 24 CFR Part 903. The previous version may be used only through April 30, 2008. 1.0 PDA Information Include the full PHA name, PHA code, PHA type, and PHA Fiscal Year Beginning (MM/YYYY). 2.0 Inventory Under each program, enter the number of Annual Contributions Contract (ACC) Public Housing (PH) and Section 8 units (HCV). 3.0 Submission Type Indicate whether this submission is for an Annual and Five Year Plan, Annual Plan only, or 5 -Year Plan only. 4.0 YHA Consortia Check box if submitting a Joint PHA Plan and complete the table. 5.0 Five -Year Plan Identify the PHA's Mission, Goals and /or Objectives (24 CFR 903.6). Complete only at 5 -Year update. 5.1 Mission. A statement of the mission of the public housing agency for serving the needs of low- income, very low- income, and extremely low- income families in thejurisdiction of the PHA during the years covered under the plan. 5.2 Coals and Objectives. Identify quantifiable goals and objectives that will enable the PHA to serve the needs of loo income, very low. income, and extremely low- income families. 6.0 PHA Plan Update. In addition to the items captured in the Plan template, PHAs most have the elements listed below readily available to the public. Additionally, a PHA must: (a) Identify specifically which plan elements have been revised since the PHA's prior plan submission. (b) Identify where the 5 -Year and Annual Plan may be obtained by the public. At a minimum, PHAs must post PHA Plans, including updates, at each Asset Management Project (AMP) and main office or central off ice of the PHA. PHAs are strongly encouraged to post complete PHA Plans on its official website. PHAs are also encouraged to provide each resident council a copy of its 5 -Year and Annual Plan. PHA Plan Elements. (24 CFR 903.7) Eligibility, Selection and Admissions Policies, including Deconcentration and Wait list Procedures. Describe the PHA's policies that govern resident or tenant eligibility, selection and admission including admission preferences for both public housing and HCV and unit assignment policies for public housing; and procedures for maintaining waiting lists for admission to public housing and address any site -based waiting lists. Financial Resources. A statement of financial resources, including a listing by general categories, of the PHA's anticipated resources, such as PHA Operating, Capital and other anticipated Federal resources available to the PHA, as well as tenant rents and other income available to support public housing or tenant -based assistance. The statement also should include the non-Federal sources of finds supporting each Federal program, and state the planned use for the resources. 3. Rent Determination. A statement of the policies of the PHA governing rents charged for public housing and HCV dwelling units. 4. Operation and Management. A statement of the rules, standards, and policies of the PHA governing maintenance management of housing owned, assisted, or operated by the public housing agency (which shall include measures necessary for the prevention or eradication of pest infestation, including cockroaches), and management of the PHA and programs of the PHA. 5. Grievance Procedures. A description of the grievance and informal hearing and review procedures that the PHA makes available to its residents and applicants. 6. Designated (lousing for Elderly and Disabled Families. With respect to public housing projects owned, assisted, or operated by the PHA, describe any projects (or portions thercoo, in the upcoming fiscal year, that the PHA has designated or will apply for designation for occupancy by elderly and disabled families. The description shall include the following information: I) development dame and number; 2) designation type; 3) application status; 4) date the designation was approved, submitted, or planned for submission, and; 5) the number of units affected. Community Service and Self- Sufficiency. A description of. (1) Any programs relating to services and amenities provided or offered to assisted families; (2) Any policies or programs of the PHA for the enhancement of the economic and social self - sufficiency of assisted families, including programs under Section 3 and FSS; (3) How the PHA wil I comply with the requirements of community service and treatment of income changes resulting from welfare program requirements. (Note; applies to only public housing). Safety and Crime Prevention. For public housing only, describe the PHA's plan for safety and crime prevention to ensure the safety of the public housing residents. The statement must include: (i) A description ofthe need for measures to ensure the safety of public housing residents; (ii) A description of any crime prevention activities conducted or to be conducted by the PHA; and (iii) A description of the coordination between the PHA and the appropriate police precincts for carrying out crime prevention measures and activities. Page I of 3 Instructions form HUD -50075 (2008) 9. Pets. A statement describing the PHAs policies and requirements pertaining to the ownership of pets in public housing. 10. Civil Rights Certification, A PHA will be considered in compliance with the Civil Rights and AFFH Certification if it can document that it examines its programs and proposed programs to identify any impediments to fair housing choice within those programs; addresses those impediments in a reasonable fashion in view of the resources available; works with the local jurisdiction to implement any of the jurisdiction's initiatives to affirmatively further fair housing; and assures that the annual plan is consistent with any applicable Consolidated Plan for itsjurisdiction. 11. Fiscal Year Audit. The results of the most recent fiscal year audit for the PHA. 12. Asset Management. A statement of how the agency will carry out its asset management functions with respect to the public housing inventory of the agency, including how the agency will plan for the long -term operating, capital investment, rehabilitation, modernization, disposition, and other needs for such inventory. 13, Violence Against Women Act (VAWA). A description of 1) Any activities, services, or programs provided or offered by an agency, either directly or in partnership with other service providers, to child or adult victims of domestic violence, dating violence, sexual assault, or stalking; 2) Any activities, services, or programs provided or offered by a PHA that helps child and adult victims of domestic violence, dating violence, sexual assault, or stalking, to obtain or maintain housing; and 3) Any activities, services, or programs provided or offered by a public housing agency to prevent domestic violence, dating violence, sexual assault, and stalking, or to enhance victim safety in assisted families. 7.0 Hope VI, Mixed Finance Modernization or Development, Demolition and /or Disposition, Conversion of Public Housing, Homeownership Programs, and Project -based Vouchers (a) Hope VI or Mixed Finance Modernization or Development. 1) A description of any housing (including project number (if known) and unit count) for which the PHA will apply for HOPE VI or Mixed Finance Modernization or Development; and 2) A timetable for the submission of applications or proposals. The application and approval process for Hope VI, Mixed Finance Modernization or Development, is a separate process. See guidance on HUD's website at: httm //\vs"v.htid.gov/offices/pili/l)rograins/pli/hope6/index.cfiu (b) Demolition and /or Disposition. With respect to public housing projects owned by the YHA and subject to ACCs under the Act: (1) A description of any housing (including project number and unit numbers [or addresses]), and the number of affected units along with their sizes and accessibility features) for which the PHA will apply or is currently pending for demolition or disposition; and (2) A timetable for the demolition or disposition. The application and approval process for demolition and/or disposition is a separate process. See guidance on HUD's website at: hRp�l/N"NM1V.IlLid.gov/offiecs/pi]Vcenters/sac/deino disoo /i idea c fm Note: This statement must be submitted to the extent that approved and /or pending demolition and /or disposition has changed. (c) Conversion of Public Housing. With respect to public housing owned by a PIIA: HA description of any building or buildings (including project number and unit count) that the PHA is required to convert to tenant -based assistance or that the public housing agency plans to voluntarily convert; 2) An analysis of the projects or buildings required to be converted; and 3) A statement of the amount of assistance received under this chapter to be used for rental assistance or other housing assistance in connection with such conversion. See guidance on HUD's website at: hut) // "vw.hud.gov/offices/Dih/ceiiters/sac/conversion.efiu (d) Homeownership. A description of any homeownership (including project number and unit count) administered by the agency or for which the PHA has applied or will apply for approval. (e) Project -based Vouchers. If the PI IA wishes to use the project -based voucher program, a statement of the projected number of project -based units and general locations and how project basing would be consistent with its PHA Plan. 8.0 Capital Improvements, 'This section provides information on a PHA's Capital Fund Program. With respect to public housing projects owned, assisted, or operated by the public housing agency, a plan describing the capital improvements necessary to ensure long -term physical and social viability of the projects must be completed along with the required forms. Items identified in 8.1 through 8.3, must be signed where directed and transmitted electronically along with the PHA's Annual Plan submission. 8.1 Capital Fund Program Annual Statement /Performance and Evaluation Report. PHAs must complete the Capital Fund Program Annual Statement /Performance and Evaluation Report (form HUD - 50075.1), for each Capital Fund Program (CFP) to be undertaken with the current year's CFP funds or with CFFP proceeds. Additionally, the form shall be used for the following purposes: (a) To submit the initial budget for a new grant or CFFP; (b) To report on the Performance and Evaluation Report progress on any open grants previously funded or CFFP; and (c) To record a budget revision on a previously approved open grant or CFFP, e.g., additions or deletions of work items, modification of budgeted amounts that have been undertaken since the submission of the last Annual Plan. The Capital Fund Program Annual Sancirient/Performance and Evaluation Report must be submitted annually. Additionally, PHAs shall complete the Performance and Evaluation Report section (see footnote 2) of the Capital Fund Program Animal SlalemenUPerforniance and Evaluation (form FIUD- 50075.1), at the following times: I. At the end of the program year; until the program is completed or all funds are expended; 2. When revisions to the Annual Statement are made, which do not require prior HUD approval, (e.g., expenditures for emergency work, revisions resulting from the PHAs application of Tangibility); and 3. Upon completion or termination of the activities funded in a specific capital fund program year. 8.2 Capital Fund Program Five -Year Action Plan PHAs must submit the Capital Fund Program Fire -Year Action Plan (form HUD - 50075.2) for the entire PHA portfolio for the first year of participation in the CFP and annual update thereafter to eliminate the previous year and to add a new fifth, year (rolling basis) so that the form always covers the present five -year period beginning with the current year. 8.3 Capital Fund Financing Program (CFFP). Separate, written HUD approval is required if the PI ]A proposes to pledge any Page 2 of3 Instructions form HUD -50075 (2008) portion of its CFP/RI IF funds to repay debt incurred to finance capital improvements. The PHA must identify in its Annual and 5- year capital plans the amount of the annual payments required to service the debt. The PHA must also submit an annual statement detailing the use of the CFFP proceeds. See guidance on HUD's website at: 11.0 I ttp' // vNv.liud.gov/offices/pilVorocranis/l)h/capftiiid/cffp.cfm 9.0 Housing Needs. Provide a statement of the housing needs of families residing in the jurisdiction served by the PHA and the means by which the PHA intends, to the maximum extent practicable, to address those needs. (Note: Standard and Troubled PHAs complete annually; Small and High Performers complete only for Annual Plan submitted with the 5 -Year Plan). 9.1 Strategy for Addressing Housing Needs. Provide a description of the FHA's strategy for addressing the housing needs of families in the jurisdiction and on the waiting list in the upcoming year. (Note: Standard and Troubled PHAs complete annually; Small and High Performers complete only for Annual Plan submitted with the 5 -Year Plan), 10.0 Additional Information. Describe the following, as well as any additional information requested by HUD: (a) Progress in Meeting Mission and Goals. PHAs must include (i) a statement of the PHAs progress in meeting the mission and goals described in the 5 -Year Plan; (ii) the basic criteria the PHA will use for determining a significant amendment from its 5 -year Plan; and a significant amendment or modification to its 5 -Year Plan and Annual Plan. (Note: Standard and Troubled PHAs complete annually; Small and High Performers complete only for Annual Plan submitted with the 5 -Year Plan). (b) Significant Amendment and Substantial Deviation /Modification. PHA must provide the definition of "significant amendment" and "substantial deviation /modification ". (Note: Standard and Troubled PHAs complete annually, Small and High Performers complete only for Annual Plan submitted with the 5 -Year Plan.) Page 3 (c) PHAs must include or reference any applicable memorandum of agreement with HUD or any plan to improve performance. (Note: Standard and Troubled PHAs complete annually). Required Submission for HUD Field Office Review. In order to be a complete package, PHAs must submit items (a) through (g), with signature by mail or electronically with scanned signatures. Items (h) and (i) shall be submitted electronically as an attachment to the PHA Plan. (a) Form HUD- 50077, PHA Certifications of Compliance wish the PHA Plans and Related Regulations (b) Form HUD- 50070, Certificationfor a Drug -Free Workplace (PHAs receiving CFP grants only) (e) Form HUD - 50071, Certification of Payments to hiuence Federal Transactions (PHAs receiving CFP grants only) (d) Form SF -LLL, Disclosure of Lobbying Activities (PHAs receiving CFP grants only) (e) Form SF- LLL -A, Disclosure of Lobbying Activities Continuation Street (PHAs receiving CFP grants only) (f) Resident Advisory Board (RAB) comments. (g) Challenged Elements. Include any element(s) of the PHA Plan that is challenged. (h) Form I IUD - 50075.1, Capital Fund Program Annual SMtement/Performance and Evaluation Report (Must be attached electronically for PHAs receiving CFP grants only). See instmetions in 8.1. (i) Form HUD- 50075.2, Capital Fund Program Five -year Action Plan (Must be attached electronically for PHAs receiving CFP grants only). See instructions in 8.2. Additional attachments available for the review in the City Clerk's Office.