HUD issued Notice H-2016-08 on August 26, 2016. This Notice relates to the Family Self Sufficiency (FSS) Program in Multifamily Housing.
FSS is a HUD program that provides incentives and support to families in MF assisted housing to increase their earned income and reduce dependence on public assistance. The program has long been used in the public housing and voucher programs, but is now available to owners of privately owned HUD-assisted multifamily housing, such as Section 8. The program is voluntary for both owners and the families living
The program is voluntary for both owners and the families living at the properties. Owners wishing to participate in the program will work with public and private resources in the development and implementation of the program. Typical family services include childcare, transportation, education, job training, employment counseling, financial literacy, and homeownership counseling. Participating families work with a five-year plan and are required to enter into an agreement with the owner. The goals are outlined in the plan, and when a family meets its goals and completes the FSS contract, they become eligible to receive funds deposited in an escrow account. The owner will establish an interest-bearing escrow account for each family. HUD will fund the account through adjustments to rental subsidy payments to the owner. If a family’s rent increases due to an increase in earned income while participating in the FSS program, the owner will credit the incremental rent due to the increase in earned income to the family’s escrow account. When a family completes the program, they may access the escrow funds and use them for any purpose. Funding Congress has not yet appropriated any funds for the employment of FSS coordinators in multifamily housing. However, owners may use residual receipts to assist in paying for the position of the FSS program coordinator. HUD may approve
HUD may approve release of residual receipts as an advance rather than a reimbursement, on a semiannual basis. No more than six months of expenses will be advanced at one time. Owners using residual receipts to pay for FSS coordinators are exempt from the requirement to use residual receipts to offset Section 8 payments.
Owners will be required to:
1. Coordinate services with local agencies;
2. Develop an Action Plan and submit to HUD for approval;
3. Recruit and screen program participants;
4. Create and execute a contract with participating families;
5. Provide service coordination, case management, or coaching;
6. Create FSS escrow accounts and manage the funds;
7. Submit quarterly reports to HUD; and
8. Comply with fair housing requirements.
Participating families will be required to:
1. Execute the contract with the owner;
2. Head of household must seek and maintain suitable employment during the term of the agreement;
3. Work with the owner to set program goals;
4. Complete required activities by established deadlines;
5. Report increases in earned income immediately;
6. Become independent from welfare assistance and remain independent for at least one year before the contract term expires (this applies to all family members); and
7. Comply with the terms of the lease.
Program Development & Approval Procedures
Owners will be required to have a HUD-approved Action Plan before implementing an FSS program. As part of the approval process, HUD will assess the owner’s ability to run an FSS program by reviewing recent Management and Occupancy Reviews (MORs) and the Financial Assessment Subsystem (FASS) score. The most recent MOR review must be Satisfactory or higher and the owner must be current in the submission of all required financial statements. The Action Plan must be comprehensive and include information on: • Family demographics; • Estimate of participating families; • FSS family selection procedures; • Incentives plan; • Outreach efforts; • FSS activities and supportive services; • Description of funding sources; • Identification of family support needs; • Owner policies regarding termination of family participation; • Rights of non-participating families; and • Timetable for program implementation. Clearly, development of an FSS program at a HUD multifamily property will be time-consuming and labor intensive. Owners will have to decide whether
The Action Plan must be comprehensive and include information on: • Family demographics; • Estimate of participating families; • FSS family selection procedures; • Incentives plan; • Outreach efforts; • FSS activities and supportive services; • Description of funding sources; • Identification of family support needs; • Owner policies regarding termination of family participation; • Rights of non-participating families; and • Timetable for program implementation. Clearly, development of an FSS program at a HUD multifamily property will be time-consuming and labor intensive. Owners will have to decide whether
Clearly, development of an FSS program at a HUD multifamily property will be time-consuming and labor intensive. Owners will have to decide whether creation of such a program will be worth the time and effort involved. One reason for consideration of the program may be the potential for extra points under State Qualified Allocation Plans (QAPs) for Section 8 properties seeking to layer Low-Income Housing Tax Credits. If a State Agency will award additional competitive points for a program such as FSS, it may be worthwhile to develop such a plan. Interested owners should obtain a copy of the Notice and examine the requirements carefully.