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Community service notice expands exemption

As noted in Thursday's blog post, HUD has published Notice PIH 2015-12 on “Administering the Community Service and Self-Sufficiency Requirement (CSSR).” The notice, which replaces Notice PIH 2009-48, was issued to assist PHAs’ understanding and administration of the CSSR and in response to an audit report from the Office of Inspector General (OIG) issued on February 13, 2015.

The new notice contains several clarifications to previous HUD guidance. First, the notice expands the exemption from the CSSR for “a member of a family receiving assistance, benefits, or services under a state program funded under part A of title IV of the Social Security Act (42 U.S.C. Section 601 et seq.), or under any other welfare program of the state in which the PHA is located, including a state-administered welfare-to-work program, and has not been found by the state or other administering entity to be in noncompliance with such a program.” According to a footnote to the notice:

HUD has determined that the Supplemental Nutrition Assistance Program (SNAP) qualifies as a welfare program of the state. Therefore, if a tenant is a member of family receiving assistance under SNAP, and has been found by the administering state to be in compliance with the program requirements, that tenant is exempt from the CSSR.

The second clarification in the new notice has to do with when non-exempt residents must complete their CSSR hours. Prior HUD guidance stated that residents were not permitted to “double up” and should complete eight hours each month of community service or self-sufficiency activities. According to the current notice:

The required community service or self-sufficiency activity may be completed at 8 hours each month or may be aggregated across a year. Any blocking of hours is acceptable as long as 96 hours is completed by each annual certification.

The new notice also contains:

  • Several suggestions for combining Family Self-Sufficiency or ROSS program activities to assist with CSSR
  • A statement that while PHAs may not substitute resident community service activities for work performed by PHA employees, residents may “assist or enhance” the work of employees through the CSSR
  • A revised Attachment B, the sample form for the required certification that non-exempt adults must sign at annual reexamination. The resident certification of compliance has been deleted, leaving only the certification of understanding of the CSSR requirement

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