Yesterday HUD’s Office of Public and Indian Housing (PIH) issued Notice PIH 2015-12 to assist PHAs’ understanding and administration of the Community Service and Self-Sufficiency Requirement (CSSR) and in response to an audit report from the Office of Inspector General (OIG) issued on February 13, 2015. PIH last provided guidance on this topic in Notice PIH 2009-48, which expired in 2010. Today's notice restates much of the earlier notice, with minor changes. The notice addresses and clarifies the following topics:
- The statutory and regulatory requirements for administering CSSR, including the definition of community service and how requirements can be met
- Administrative provisions, including developing a local CSSR policy, administering qualifying activities, and what the PHA must and should do in order to give back to the community and help residents fulfill their community service obligations
- What eligible community services and self-sufficiency activities include, but are not limited to
- That PHAs with a ROSS program, ROSS Service Coordinators, or FSS program may coordinate individual training and services plans (ITSPs) with CSSR, and other possible CSSR partnerships
- Which residents are exempt, as must be described in a PHA’s admissions and continued occupancy policy (ACOP), and how the final determination for exemption is made
- Resident responsibilities, what to do about noncompliant residents, and how monitoring reports figure into alerting PHAs of noncompliance issues
- The prohibition of CSSR for work ordinarily performed by PHA employees
- Documentation, including enforcement documentation, CSSR completion, and 50058 coding
- Sanctions for noncompliant PHAs
As did the previous notice, today's notice includes two attachments meant for nonexempt individuals to sign and date, one certifying entrance acknowledgement for the CSSR requirement, and one for annual renewal. Contact information for PHAs who would like to request any further information regarding the notice is also included. Notice PIH 2015-12 will be effective until amended or superseded.
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