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Working with sequestration in the HCV program: Part III

Teri RobertsonSequester or no sequester, housing authorities have a business to run. And a complicated business it is! The HCV and public housing programs have so many moving parts — and so many regulatory requirements — that it has to be one of the most demanding businesses to be in. Reduced funding simply makes a challenging job that much more challenging.

One of the challenges in working at a housing authority is finding the balance: How large should caseload sizes be to ensure efficiency without sacrificing effectiveness? How often should we purge our waiting list to offset the cost of the work with the benefit of having only people still interested in the program at the top of the waiting list? And, critical in these times, how do we maintain a healthy program size while dealing with reduced administrative fees?

Eliminating face-to-face annual reexams

There is no HUD requirement to conduct face-to-face annual reexamination interviews. Many PHAs actually conduct all annual reexaminations completely by mail, following up by telephone if clarification is necessary. Of course, this means that the agency needs to have a clear and comprehensive annual reexamination family declaration so as to minimize the need for that follow-up contact by either party.

Not all agencies are comfortable implementing a policy that could result in never seeing some families face-to-face. Here are some ideas that offer a middle-of-the-road approach:

Idea #1: See all families for a face-to-face interview with every other annual reexamination.

Moving to Work (MTW) agencies typically adopt the policy of conducting reexaminations every other year, rather than annually. If yours is not an MTW agency, you do not have that option. However, you could put into place a policy that would allow you to conduct face-to-face interviews with the annual reexamination only every other year.

Idea #2: Decide which families should be seen each year, and only require face-to-face interviews for those families.

Conduct annual reexaminations by mail for all other families. Ensure that your policy allows for a face-to-face interview if your agency decides the need exists, or if the family requests the interview. Families that will be seen every year might include:

Working families. Rationale:

  • Many working individuals change jobs frequently.
  • Correct calculation of wages is one of the problem areas for most agencies.

Zero-income families. Rationale:

  • Often, these families are withholding income information that an effective interview will be able to uncover.

Families with a fraud history. Rationale:

  • Families that have withheld information in the past are probably more likely to withhold information in the future. Effective interviewing may prevent this.

Families that do not respond to annual reexamination mailings in a timely manner. Rationale:

  • If the family delays return of the annual reexamination packet, the PHA still must meet its annual reexamination deadline.
  • Requiring families who delay in completing and returning their completed annual reexamination (by mail) packet to come into the office can promote timely return of information.
  • Families who respond in a timely manner, but with incomplete information and/or documents, should also be called in for a face-to-face interview.

If ever there was a time to significantly change the way we conduct business so as to reduce administrative burdens, the time is now. We are still held to program requirements. Let's eliminate or reduce those actions we currently have in place that are not required by HUD.

NMA senior consultant Teri Robertson is nationally recognized as a leading expert in HCV/Section 8 and public housing. She has previously written for the NMA blog about HCV administrative fees and how to maximize your agency’s performance rating.

If you find that you need staffing help during sequestration, NMA can assist your agency with recertifications (done remotely), quality control, hearing officer staff, HQS inspections, and more. Email sales@nanmckay.com for more information.