Item HA 03 - Housing Choice Voucher Administrative Plan

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Housing Choice Voucher Administrative Plan August 6, 2024 Page 2 a transition plan described in Section 475(5)(H) of the Social Security Act, and are homeless or are at risk of becoming homeless at age 16 or older. Through effective partnerships with the United Way of Orange County, Orange County Social Services Agency (e.g. our local PCWA), and Orangewood Foundation, the Santa Ana Housing Authority has one of the highest FYI voucher utilization rates in southern California, successfully housing and providing supportive services for this at -risk target population in our community. Recently, staff became aware that the Housing Authority was out of compliance with the federal regulations for 15 of our FYI voucher holders. Staff immediately brought this to the attention of HUD to request approval to continue assisting these 15 FYI voucher holders for the additional time staff assumed was remaining under a 24-month extension. Specifically, HUD Notice Public and Indian Housing 2023-4 states, "As required by statute, an FYI voucher may only be used to provide housing assistance for youth for a maximum of 36 months. However, youth who first lease a unit with an FYI voucher after the date of enactment of the Fostering Stable Housing Opportunities (FSHO) amendments may receive an extension of the 36-month time limit of assistance for up to an additional 24 months if they meet the requirements of FSHO. FSHO applies to eligible youth who first leased or leases a unit after the date of enactment of FSHO, December 27, 2020, which includes youth who will be assisted with funding under this Notice." FSHO provides a 24-month extension of voucher assistance for FYI voucher holders who are participating in a Family Self -Sufficiency (FSS) program. It is staff's position that the information on this 24-month extension opportunity was not properly communicated to the Housing Authority or other PHAs. Specifically, it was not communicated transparently and effectively that the 24-month extension only applied to FYI voucher holders who leased up after December 27, 2020. When the Housing Authority first learned about the 24-month extension opportunity, staff encouraged and registered our first cohort of FYI vouchers that leased up prior to December 27, 2020 to join our FSS Program. These 15 FYI voucher holders are now active in our FSS Program and still receive assistance as FYI voucher holders. Unfortunately, based upon recent guidance staff received from HUD, these 15 FYI voucher holders are not eligible for continued assistance due to the December 27, 2020 statutory deadline. Therefore, in order to comply with this statutory requirement and to prevent the termination of these 15 FYI voucher holders now and other FYI voucher holders in the future, staff is recommending approval of an update to Chapter 4-III.C. of the HCV Administrative Plan to include a preference to assist FYI voucher holders who reach the deadline on their assistance. This update will create a preference in our regular HCV program for FYI voucher holders whose assistance is expiring. Administratively, the preference will allow the Housing Authority to transfer the expiring FYI voucher holder to a regular Housing Choice Voucher (HCV) and absorb the FYI voucher into the larger HCV Program. This will ensure that FYI voucher holders assisted by SAHA do not lose their assistance after 3 to 5 years due to the statutory timelines required by the FYI