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B. The application must include a statement that (1) the Administrative Plan contains all <br />required PBV policies and (2) the application for HUD-VASH funding under this <br />competition is consistent with the PHA’s administrative policies and PHA Plan. For <br />administrative plan policies, please reference sections 2.a.(1), (2), (3), (6), and (7) of <br />Notice PIH 2011–54 (Guidance on the Project-Based Voucher Program). For the PHA <br />Plan, please reference section 2.b. of that Notice. The signature on the application will <br />serve as a certification of this statement. For those applications where a project will <br />be selected after awards are announced, PHAs must submit this certification with the <br />notification of the selected project, within six months of award announcement. <br /> <br />C. The application must include a statement that the PHA will enforce compliance with <br />a Housing First approach at the project. If a project has been selected prior to the <br />application under this Notice, the application must include a signed statement from <br />the project owner that the project will comply with a Housing First approach. If a <br />project is selected after award announcement, a signed statement from the project <br />owner that the project will comply with a Housing First approach must be submitted <br />to HUD within 6 months after award announcement. <br /> <br />Housing First is an approach where homeless persons, usually chronically homeless or <br />especially vulnerable homeless individuals and families, are provided immediate <br />access to housing and then offered the supportive services that may be needed to foster <br />long-term stability and prevent a return to homelessness. This approach removes <br />unnecessary barriers and assumes that supportive services are more effective in <br />addressing needs when the individual or family is housed and the daily stress of being <br />homeless is addressed. Key components of this model include a simple application <br />process, a harm reduction approach, and no conditions of tenancy beyond those <br />included in the lease. Housing First specifically does not require sobriety or testing <br />for substance abuse to obtain or sustain tenancy and thus must not be required in the <br />lease. In serving these populations, projects cannot discriminate against families with <br />children. More information on Housing First is available at: <br />https://www.hudexchange.info/resources/documents/Housing-First-Permanent- <br />Supportive-Housing-Brief.pdf . <br /> <br />D. The PHA applicant must not have any major unresolved program management <br />findings from an Inspector General audit, HUD management review, or Independent <br />Public Accountant (IPA) audit for the PHA’s HCV program or other significant <br />program compliance programs that were not resolved or in the process of being <br />resolved (as determined by the local field office) prior to this Notice’s application <br />deadline. Major program management findings or significant program compliance <br />problems are those that inhibit the capacity of the applicant to effectively administer a <br />HUD-VASH PBV project. In addition, the PHA must not be involved in litigation <br />that HUD determines may seriously impede the ability of the applicant to administer <br />the HUD-VASH PBV project. The local HUD field office will provide the necessary <br />information on this factor. <br /> <br />7-9