Admissions & Continued Occupancy Policy (ACOP) - PROPOSED REVISIONS FOR FY 2019 DURHAM HOUSING AUTHORITY-PUBLIC HOUSING PROGRAM
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FY 2019 Admissions & Continued Occupancy Policy (ACOP) PROPOSED REVISIONS FOR FY 2019 DURHAM HOUSING AUTHORITY-PUBLIC HOUSING PROGRAM
Public Housing Admissions & Continued Occupancy Policy (ACOP)
Proposed Revisions for FY 2019
ACOP Proposed New Language
ACOP Current Language
Section (Changes are BOLD and HIGHLIGHTED)
Exhibit 3-2: ELIGIBILITY DETERMINATION STANDARDS Exhibit 3-2: ELIGIBILITY DETERMINATION STANDARDS
Sex Offense Involving Children or Adults DENY FOR Sex Offense Involving Children or Adults DENY 5
LIFE years
Abuse Involving Children DENY FOR Abuse Involving Children DENY 5
LIFE years
Registered State Sex Offender DENY FOR Registered State Sex Offender DENY FOR
Exhibit LIFE LIFE
3-2 Manufacturing Methamphetamine DENY FOR Manufacturing Methamphetamine DENY FOR
(Speed) LIFE (Speed) LIFE
(Drugs) Use (without evidence of Deny 5 (Drugs) Use (without evidence of Deny 5
rehabilitation) years rehabilitation) years
(Drugs) Possession Deny 3 (Drugs) Possession Deny 3
years years
Arrest or conviction-posed a threat to Deny 5 Arrest or Conviction-posed a threat to Deny 5
DHA staff or residents years DHA staff or residents years
4-I.B. APPLYING FOR ASSISTANCE 4-I.B. APPLYING FOR ASSISTANCE
DHA POLICY DHA POLICY
….Families may obtain application forms from the site ….Families may obtain application forms from the Site they
they are applying for during normal business hours. are applying for during the times designated by the site,
Families may also request – by telephone or by mail – or from the DHA website. Families may also request – by
that a form be sent to the family via first class mail. telephone, mail, or e-mail – that a form be sent to the
4-I.B family via first class mail or e-mail.
Completed applications must be returned to the site
the applicant is applying for by mail, by fax, or Completed applications must be returned to the Site the
submitted in person during normal business hours. applicant is applying for by mail, fax, e-mail, or in person
Applications must be complete in order to be accepted during the times designated by the site. Applications must
by DHA for processing. If an application is incomplete, be complete in order to be accepted by DHA for
DHA will notify the family of the additional information processing. If an application is incomplete, DHA will notify
required. the family of the additional information required.
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ACOP Current Language
Section (Changes are BOLD and HIGHLIGHTED)
Families may also apply using the Online Application
Portal when available.
4-I.D. PLACEMENT ON THE WAITING LIST 4-I.D. PLACEMENT ON THE WAITING LIST
Eligible for Placement on the Waiting List Eligible for Placement on the Waiting List
DHA Policy DHA Policy
DHA will mail written notification of the preliminary DHA will mail written notification of the preliminary
eligibility determination within 10 business days of eligibility determination within 10 business days of
receiving a completed application. If applicable, the receiving a completed application. If applicable, the
notice will also indicate the waiting list preference(s) notice will also indicate the waiting list preference(s) for
4-I.D for which the family appears to qualify. which the family appears to qualify.
Placement on the waiting list does not indicate that Placement on the waiting list does not indicate that the
the family is, in fact, eligible for admission. A final family is, in fact, eligible for admission. A final
determination of eligibility and qualification for determination of eligibility and qualification for
preferences will be made when the family is selected preferences will be made when the family is selected from
from the waiting list. the waiting list.
4-II.F. UPDATING THE WAITING LIST 4-II.F. UPDATING THE WAITING LIST
HUD requires DHA to establish policies to use when removing HUD requires DHA to establish policies for removing applicant
applicant names from the waiting list [24 CFR names from the waiting list [24 CFR 960.202(a)(2)(iv)].
960.202(a)(2)(iv)].
Purging the Waiting List
4-II.F Purging the Waiting List
The decision to withdraw an applicant family that includes a
The decision to withdraw an applicant family that includes a person with disabilities from the waiting list is subject to
person with disabilities from the waiting list is subject to reasonable accommodation. If the applicant did not respond to
reasonable accommodation. If the applicant did not respond DHA’s request for information or updates because of the family
to DHA’s request for information or updates because of the member’s disability, DHA must, upon the family’s request,
family member’s disability, DHA must, upon the family’s reinstate the applicant family to their former position on the
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request, reinstate the applicant family to their former position waiting list as a reasonable accommodation [24 CFR 8.4(a), 24 CFR
on the waiting list as a reasonable accommodation [24 CFR 100.204(a), and PH Occ GB, p. 39 and 40]. See Chapter 2 for further
8.4(a), 24 CFR 100.204(a), and PH Occ GB, p. 39 and 40]. See information regarding reasonable accommodations.
Chapter 2 for further information regarding reasonable
accommodations. DHA Policy
The site-based waiting list will be purged at least annually
DHA Policy or more frequently as needed to ensure that all applicants
The site based waiting list will be updated on a and applicant information is current and timely.
quarterly basis to ensure that all applicants and
applicant information is current and timely.
7-III.E. ASSETS AND INCOME FROM ASSETS 7-III.E. ASSETS AND INCOME FROM ASSETS
Family Declaration of Assets Under $5,000 [24 CFR 960.259]
DHA will obtain third-party verification of all family assets upon
admitting a family to the public housing program, and at least
Assets Disposed of for Less than Fair Market Value
every three (3) years thereafter.
The family must certify whether any assets have been
disposed of for less than fair market value in the preceding
DHA Policy
two years. DHA needs to verify only those certifications that
For a family with net assets equal to or less than $5,000, DHA
warrant documentation [HCV GB, p. 5-28].
will accept for purposes of annual reexamination only, a family’s
7-III.E
certification that is has net assets equal to or less than $5,000.
The declaration will state the amount of income the family
expects to receive from such assets; this amount will be
included in the family’s income.
DHA will obtain third-party verification of all family assets every
three (3) years.
All family members 18 years or older will be required to sign the
declaration of total assets.
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Whenever a family member is added DHA will obtain third-party
verification of that family member’s assets. If the addition of
that family member’s assets puts the family above the $5,000
asset threshold, DHA will obtain third-party verification of the
entire family’s assets at the next annual reexamination. If the
addition of that family member’s assets does not put the family
above the $5,000 asset threshold, then DHA will not obtain
third-party verification of the entire family’s assets at the next
reexamination; however, third party verification of all family
assets is required at least every three (3) years.
Assets Disposed of for Less than Fair Market Value
The family must certify whether any assets have been disposed of
for less than fair market value in the preceding two years. DHA
needs to verify only those certifications that warrant
documentation [HCV GB, p. 5-28].
7-III.C. PERIODIC PAYMENTS AND PAYMENTS IN LIEU OF 7-III.C. PERIODIC PAYMENTS AND PAYMENTS IN LIEU OF
EARNINGS EARNINGS
Social Security/SSI Benefits Social Security/SSI Benefits
DHA Policy DHA Policy
To verify the SS/SSI benefits of applicants, DHA will To verify the SS/SSI benefits of applicants, DHA will request
request a current (dated within the last 60 days) SSA a current (dated within the last 60 days) SSA benefit
7-III.C benefit verification letter from each family member verification letter from each family member that receives
that receives social security benefits. If the family is social security benefits. If the family is unable to provide
unable to provide the document(s), DHA will ask the the document(s), DHA will ask the family to request a
family to request a benefit verification letter by either benefit verification letter by either calling SSA at 1-800-
calling SSA at 1-800-772-1213, or by requesting it from 772-1213, or by requesting it from www.ssa.gov. Once the
www.ssa.gov. Once the applicant has received the applicant has received the benefit verification letter they
will be required to provide it to DHA.
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benefit verification letter they will be required to
provide it to DHA. To verify the SS/SSI benefits of residents, DHA will obtain
information about social security/SSI benefits through the
To verify the SS/SSI benefits of residents, DHA will HUD EIV System or the Tenant Assessment Subsystem
obtain information about social security/SSI benefits (TASS). If benefit information is not available in HUD
through the HUD EIV System or the Tenant systems, DHA will request a current SSA benefit
Assessment Subsystem (TASS). If benefit information verification letter from each family member that receives
is not available in HUD systems, DHA will request a social security benefits. If the family is unable to provide
current SSA benefit verification letter from each family the document(s) DHA will ask the family to request a
member that receives social security benefits. If the benefit verification letter by either calling SSA at 1-800-
family is unable to provide the document(s) DHA will 772-1213, or by requesting it from www.ssa.gov. Once the
ask the family to request a benefit verification letter resident has received the benefit verification letter they
by either calling SSA at 1-800-772-1213, or by will be required to provide it to DHA.
requesting it from www.ssa.gov. Once the resident has
received the benefit verification letter they will be To verify the benefits of residents when 100 percent of
required to provide it to DHA. the family’s income consists of Social Security payments
to include Supplemental Security Income (SSI) and
Supplemental Security Disability Insurance (SSDI), DHA
will recalculate family income by applying the Social
Security Administrations published cost of living
adjustments to the previously verified income amount.
8-I.E. SECURITY DEPOSITS [24 CFR 966.4(b)(5)] 8-I.E. SECURITY DEPOSITS [24 CFR 966.4(b)(5)]
At the option of DHA, the lease may require security deposits. At the option of DHA, the lease may require security deposits. The
The amount of the security deposit cannot exceed a amount of the security deposit cannot exceed a reasonable fixed
8-I.E. reasonable fixed amount as determined by DHA. Subject to amount as determined by DHA. Subject to applicable laws, security
applicable laws, security deposits may be refunded to the deposits may be refunded to the tenant after vacating the unit, or
tenant after vacating the unit, or used for tenant services or used for tenant services or activities.
activities.
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DHA Policy DHA Policy
DHA will require the resident to pay the full amount of DHA will require the resident to pay the full amount of the
the deposit on or before the occupancy date unless deposit on or before the occupancy date unless waived
waived under an official marketing promotion that is under an official marketing promotion that is approved by
approved by the CEO or designee. the CEO or designee.
The security deposit shall be an amount equal to one
month’s total tenant payment or a fixed amount $300. The security deposit shall be an amount equal to one month’s
total tenant payment or a fixed amount $300.
PART II: INSPECTIONS PART II: INSPECTIONS
8-II.B. TYPES OF INSPECTIONS 8-II.B. TYPES OF INSPECTIONS
Move-Out Inspections [24 CFR 966.4(i)] Move-Out Inspections [24 CFR 966.4(i)]
DHA must inspect the unit at the time the resident vacates the DHA must inspect the unit at the time the resident vacates the unit
unit and must allow the resident to participate in the and must allow the resident to participate in the inspection if he or
8-II.B
inspection if he or she wishes, unless the tenant vacates she wishes, unless the tenant vacates without notice to DHA. DHA
without notice to DHA. DHA must provide to the tenant a must provide to the tenant a statement of any charges to be made
statement of any charges to be made for maintenance and for maintenance and damage beyond normal wear and tear within
damage beyond normal wear and tear. 30 days of move-out.
PART I: COMMUNITY SERVICE REQUIREMENT PART I: COMMUNITY SERVICE REQUIREMENT
11-I.B. REQUIREMENTS 11-I.B. REQUIREMENTS
Definitions Definitions
Exempt Individual [24 CFR 960.601(b), Notice PIH 2009-48] Exempt Individual [24 CFR 960.601(b), Notice PIH 2009-48]
11-I.B
An exempt individual is an adult who: An exempt individual is an adult who:
Is in a family receiving assistance under a state Is in a family receiving assistance under a state program
program funded under part A of title IV of the Social funded under part A of title IV of the Social Security Act, or
Security Act, or under any other welfare program of under any other welfare program of the state in which
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the state in which DHA is located, including a state- DHA is located, including a state-administered welfare-to-
administered welfare-to-work program, and has not work program, and has not been found by the state or
been found by the state or other administering entity other administering entity to be in noncompliance with
to be in noncompliance with such program. such program. HUD has determined that the
Supplemental Nutrition Assistance Program (SNAP)
qualifies as a welfare program of the state.
12-I.E VAWA EMERGENCY TRANSFER POLICY
I. PURPOSE AND APPLICABILITY
The purpose of this policy is to implement the requirements of the
Violence Against Women Act (VAWA) with respect to the
responsibilities of DHA regarding domestic violence, dating
[NEW SECTION] violence, sexual assault and stalking. This policy shall be
applicable to the Public Housing Program, administered by DHA
and shall be part of the Public Housing Admissions & Continued
Occupancy Policy. Protections under this policy are available to all
victims regardless of sex, gender identity, or sexual orientation and
NEW
will be applied consistent with all nondiscrimination and fair
SECTION
housing requirements.
12-I.E
II. GOALS AND OBJECTIVES
A. Maintaining compliance with all applicable legal requirements
imposed by VAWA
B. Ensuring the physical safety of victims of actual or threatened
domestic violence, dating violence, sexual assault and stalking
C. Providing and maintaining housing opportunities for victims of
domestic violence, dating violence, sexual assault and stalking
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D. Creating and maintaining collaborative arrangements between
DHA, law enforcement authorities, victim service providers and
[NEW SECTION] others to promote the safety and well-being of victims of actual or
threatened domestic violence, dating violence, sexual assault and
stalking
E. Taking appropriate action in response to an incident or incidents
of domestic violence, dating violence, sexual assault and stalking
affecting individuals assisted by DHA.
III. DEFINITIONS
A. Domestic Violence - includes felony or misdemeanor
crimes of violence committed by a current or former spouse or
intimate partner of the victim, by a person with whom the
victim shares a child, by a person who is living with or has lived
with the victim as a spouse or intimate partner, by a person
[NEW SECTION] similarly situated to a spouse of the victim under the domestic
or family violence laws of the jurisdiction receiving grant
monies, or by any other person against an adult or youth victim
who is protected from that person's acts under the domestic or
family violence laws of the jurisdiction.
B. Spouse or Intimate Partner - includes a person who is or
has been in a social relationship of a romantic or intimate
nature with the victim, as determined by the length of the
relationship, the type of the relationship, and the frequency of
interaction between the persons involved in the relationship.
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C. Dating Violence - violence committed by a person who is or
has been in a social relationship of a romantic or intimate
nature with the victim and where the existence of such a
relationship is determined by the length of the relationship,
the type of the relationship, and the frequency of interaction
between the persons involved in the relationship.
D. Sexual Assault - is any type of sexual contact or behavior that
occurs without the explicit consent of the recipient, including
when the individual lacks capacity to consent
E. Stalking - engaging in a course of conduct directed at a
specific person that would cause a reasonable person to fear for
the person's individual safety or the safety of others, or suffer
substantial emotional distress
F. Affiliated individual - with respect to an individual, means
(1) A spouse, parent, brother, sister, or child of that individual, or
[NEW SECTION] a person to whom that individual stands in the place of a parent or
guardian (for example, the affiliated individual is a person in the
care, custody, or control of that individual); or
(2) Any other person living in the household of that individual
G. Perpetrator - a person who commits acts of domestic violence,
dating violence, sexual assault, or stalking against a victim
IV. NOTIFICATIONS PROVIDED
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A. All applicants and tenants of the Public Housing Program
will be provided HUD-5380, "Notification of Occupancy Rights
Under the Violence Against Women Act (VAWA)" and HUD-5382,
"Certification of Domestic Violence, Dating violence, Sexual
Assault, or Stalking and Alternate Documents" at the following
times:
(1) Denial of assistance or
(2) Eligibility screening for assistance or
(3) Termination of assistance
(4) Annual Recertification
B. These forms will be provided in the applicable language, if
necessary, in accordance with Executive Order 13166 (Improving
Access to Services for Persons with Limited English Proficiency).
V. ELIGIBILITY SCREENING
A. Non-Denial of Assistance – DHA will not deny assistance
[NEW SECTION] to any person because that person is or has been a victim of
domestic violence, dating violence, sexual assault, or stalking,
provided that such person is otherwise qualified for admission.
B. Mitigation of Disqualifying Information
(1) An applicant for assistance whose history
includes incidents in which the applicant was a
victim of domestic violence, may request that DHA
take such information into account in mitigation
of potentially disqualifying information, such as
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poor credit history or previous damage to a
dwelling.
(2) If requested by an applicant to take such
mitigating information into account, DHA shall be
entitled to conduct such inquiries as are
reasonably necessary to verify the claimed history
of domestic violence and its probable relevance to
the potentially disqualifying information.
(3) DHA will not disregard or mitigate
potentially disqualifying information if the
applicant household includes a perpetrator of a
previous incident or incidents of domestic
violence.
VI. TERMINATION OF ASSISTANCE
A. VAWA Protections
[NEW SECTION]
(1) A tenant may not be terminated solely on the basis
of criminal activity directly relating to domestic
violence, dating violence, sexual assault, or
stalking if:
a. the criminal activity is engaged in by a member of
the household of the tenant or any guest or other
person under the control of the tenant and
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b. the tenant or an affiliated individual of the tenant
is the victim or threatened victim of such
domestic violence, dating violence, sexual assault,
or stalking
(2) An incident of actual or threatened domestic
violence, dating violence, sexual assault, or stalking shall
not be considered as a serious or repeated violation of the
lease by the victim or threatened victim or good cause for
terminating the assistance, of the victim or threatened
victim of such incident.
B. Limitations of VAWA Protections
(1) Nothing in the above section limits the authority of DHA to
comply with a court order with respect to the rights of
access or control of property, including civil protection
orders issued to protect a victim of domestic violence,
[NEW SECTION] dating violence, sexual assault, or stalking, or the
distribution or possession of property among members of
a household.
(2) Nothing in the above section limits any available authority
of DHA to terminate assistance to a tenant for any
violation not premised on an act of domestic violence,
dating violence, sexual assault, or stalking. However, DHA
will not hold to a more demanding standard, an applicant,
tenant or an affiliated individual who is or has been a
victim of or domestic violence, dating violence, sexual
assault, or stalking
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(3) Nothing in the above section limits the authority of DHA
to terminate from assistance any tenant or lawful
applicant if
a. DHA can demonstrate an actual and imminent
threat to other tenants or to those employed at
or providing service to the property, if the
tenant is not terminated from the program,
and
b. No other actions that could be taken to reduce
the threat have been successful, including
transferring the victim to a different unit,
barring the perpetrator from the assisted unit,
involving law enforcement, or seeking other legal
remedies to prevent the perpetrator from
acting on a threat.
V I I . VERIFICATION OF DOMESTIC VIOLENCE, DATING
[NEW SECTION] VIOLENCE, SEXUAL ASSAULT, OR STALKING
A. Requirement for Verification. Subject only to waiver as
provided in paragraph D below, DHA shall require
verification in all cases where an individual requests
protection against an action involving domestic violence,
dating violence, sexual assault, or stalking. Verification may
be accomplished in one of three ways:
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(1) Completing HUD-5382, "Certification of Domestic
Violence, Dating Violence, Sexual Assault, or
Stalking"
(2) Other documentation signed by an employee,
agent, or volunteer of a victim service provider, an
attorney, or a medical professional, from whom
the victim has sought assistance in addressing
domestic violence, dating violence, sexual assault,
or stalking, or the side effects of the abuse,
described in such documentation. The
professional providing the documentation must
sign and attest under penalty of perjury that the
incident or incidents in question are bona fide and
meet the requirements of the applicable definition
set forth in this policy.
(3) Police or court record - provided to DHA by
federal, state, tribal, or local police or court
record describing the incident or incidents in
question.
[NEW SECTION]
B. Time Allowed. An individual who claims protection against
adverse action based on an incident or incidents of actual or
threatened domestic violence, dating violence, sexual
assault or stalking, and who is requested by DHA to provide
verification, must provide such verification within 14
business days after receipt of the request for verification.
Failure to provide verification, in proper form within such
time will result in loss of protection under VAWA and this
policy against a proposed adverse action.
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C. If DHA receives conflicting evidence that an incident of
domestic violence, dating violence, sexual assault, or
stalking has been committed (such as certification forms
from two or more members of a household each claiming to
be a victim and naming one or more of the other petitioning
household members as the abuser or perpetrator), DHA has
the right to request that the tenant provide third-party
documentation within thirty 30 calendar days in order to
resolve the conflict. Failure to provide third-party
documentation where there is conflicting evidence will
result in loss of protection under VAWA and this policy
against a proposed adverse action.
D. Waiver of verification requirement. With respect to any
specific case, DHA may waive the above-stated
requirements for verification and provide the benefits of
this policy based on the victim’s statement or other
corroborating evidence. Such waiver may be granted
[NEW SECTION] in the sole discretion of the Program Director or CEO.
Any such waiver must be in writing. Waiver in a particular
instance or instances shall not operate as precedent for, or
create any right to, waiver in any other case or cases,
regardless of similarity in circumstances.
VIII. EMERGENCY TRANSFER PLAN
A. Eligibility for Transfer
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In accordance with the Violence Against Women Act
(VAWA) DHA allows tenants who are victims of domestic
violence, dating violence, sexual assault, or stalking to
request an emergency transfer from the tenant’s current
unit to another unit, regardless of sex, gender identity, or
sexual orientation. The ability of DHA to honor such
request for tenants currently receiving assistance may
depend upon:
(1) A preliminary determination that the tenant is
or has been a victim of domestic violence,
dating violence, sexual assault, or stalking, and
(2) On whether DHA has another dwelling unit that
is available and is safe to offer the tenant for
temporary or more permanent occupancy.
[NEW SECTION] B. Requesting a transfer
(1) In order to request an emergency transfer the tenant
shall notify DHA by submitting a written request for a
transfer (HUD-5383). DHA will provide reasonable
accommodations to this policy for individuals with
disabilities. In addition to submitting the HUD-5383,
the tenant 's written request for an emergency
transfer should also include either:
a. A statement expressing that the tenant
reasonably believes that there is a threat of
imminent harm from further violence if the tenant
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were to remain in the same dwelling unit assisted
under the PH program; or
b. A statement that the tenant was a sexual assault
victim and that the sexual assault occurred on the
premises during the 90-calendar-day period
preceding the tenant’s request for an emergency
transfer.
(2) DHA cannot guarantee that a transfer request will be
approved or how long it will take to process a transfer
request. However, DHA will act as quickly as possible
to expedite and finalize the move of a tenant who is
a victim of domestic violence, dating violence, sexual
assault, or stalking to another unit, subject to
availability and safety of a unit.
[NEW SECTION]
(3) If a tenant believes a transfer within DHA’s
jurisdiction would not be safe, the tenant may
request an external transfer to a different PHA.
DHA will assist the tenant by completing a form
indicating that the tenant is a victim of domestic or
sexual violence and is eligible for a VAWA
emergency transfer and that DHA does not have a
safe unit immediately available.
(4) If a unit is available, the transferred tenant must
agree to abide by the terms and conditions that
govern occupancy in the unit to which the tenant has
been transferred. DHA may be unable to transfer a
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ACOP Current Language
Section (Changes are BOLD and HIGHLIGHTED)
tenant to a particular unit if the tenant cannot
establish eligibility for that unit.
(5) In cases where DHA determines that the family’s
decision to move out of public housing was
reasonable under the circumstances, then DHA may
wholly or partially waive rent payments and any rent
owed shall be reduced by the amounts of rent
collected for the remaining lease term from a tenant
subsequently occupying the unit.
(6) Should for any reason DHA be unable to successfully
process/facilitate the tenant’s emergency transfer,
DHA will refer the tenant to other housing providers
who may have safe and available units to which the
tenant could move.
(7) At the tenant’s request, DHA will also assist tenants
in contacting the local organizations offering
[NEW SECTION] assistance to victims of domestic violence, dating
violence, sexual assault, or stalking.
C. Family Break-Up Affecting a Tenant’s Emergency Move
If the family breakup results from the occurrence of
domestic violence, dating violence, sexual assault or
stalking, DHA must ensure that the victim retains
assistance. DHA will act accordingly as follows:
(1) Should the victim wish to remain in the currently
occupied unit, the unit will remain with the victim, as
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long as the victim agrees to have the perpetrator
removed from the lease agreement and thereby
removed from the household composition
(2) Should the victim wish to request an emergency
move, DHA will provide the victim a voucher to
search for housing and expedite the applicable
change of unit processes in order to facilitate a
quicker move for the victim. DHA will also terminate
the assistance of the perpetrator and remove
him/her from the household composition
D. Safety and Security of Tenants
(1) Confidentiality - DHA will keep confidential any
information that the tenant submits in requesting an
emergency transfer, and information about the
emergency transfer, unless the tenant gives
DHA written permission to release the information
[NEW SECTION] on a time limited basis, or disclosure of the
information is required by law or required for use in
an eviction proceeding or hearing regarding
termination of assistance from the covered program.
This includes keeping confidential the new
location of the dwelling unit of the tenant, if one
is provided, from the person(s) that committed an
act(s) of domestic violence, dating violence, sexual
assault, or stalking against the tenant.
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(2) Pending processing of the transfer and the actual
transfer, if it is approved and occurs, the tenant
is urged to take all reasonable precautions to be safe.
(3) Tenants who are or have been victims of domestic
violence are encouraged to contact the National
Domestic Violence Hotline at 1-800-799-7233, or a
local domestic violence shelter, for assistance in
creating a safety plan. For persons with hearing
impairments, that hotline can be accessed by calling
1-800-787-3224 (TTY).
(4) Tenants who have been victims of sexual assault may
[NEW SECTION] call the Rape, Abuse & Incest National Network’s
National Sexual Assault Hotline at 800-656-HOPE, or
visit the online hotline at
https://ohl.rainn.org/online/.
(5) Tenants who are or have been victims of stalking
seeking help may visit the National Center for Victims
of Crime’s Stalking Resource Center at
https://www.victimsofcrime.org/our-
programs/stalking-resource-center.
IX. OTHER REMEDIES
A. Relationships with service providers
It is the policy of DHA to cooperate with organizations and
entities, both private and governmental that provide shelter
and/or services to victims of domestic violence. If DHA becomes
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aware that an individual assisted by the Housing Authority is a
victim of domestic violence, dating violence, sexual assault or
stalking, DHA will refer the victim to such providers of shelter or
services as appropriate. Notwithstanding the foregoing, this
policy does not create any legal obligation requiring DHA either
to maintain a relationship with any particular provider of shelter
or services to victims of domestic violence or to make a
referral in any particular case.
13-III.B CHAPTER 13 PART III: TERMINATION BY DHA – OTHER CHAPTER 13 PART III: TERMINATION BY DHA – OTHER
AUTHORIZED REASONS AUTHORIZED REASONS
13-III.B. MANDATORY LEASE PROVISIONS [24 CFR 966.4(I)(5)] 13-III.B. MANDATORY LEASE PROVISIONS [24 CFR 966.4(I)(5)]
Illegal Use of a Drug [24 CFR 966.4(l)(5)(i)(B)] Illegal Use of a Drug [24 CFR 966.4(l)(5)(i)(B)]
The lease must provide that a DHA may evict a family when The lease must provide that a DHA may evict a family when DHA
DHA determines that a household member is illegally using a determines that a household member is illegally using a drug or
drug or that a pattern of illegal use of a drug interferes with that a pattern of illegal use of a drug interferes with the health,
the health, safety, or right to peaceful enjoyment of the safety, or right to peaceful enjoyment of the premises by other
premises by other residents. residents.
DHA Policy DHA Policy
DHA will terminate the lease when DHA determines DHA will terminate the lease when DHA determines that a
that a household member is illegally using a drug or household member is illegally using a drug or DHA
DHA determines that a pattern of illegal use of a drug determines that a pattern of illegal use of a drug interferes
interferes with the health, safety, or right to peaceful with the health, safety, or right to peaceful enjoyment of
enjoyment of the premises by other residents. the premises by other residents.
A pattern of illegal drug use means more than one incident
of any use of illegal drugs during the previous six months.
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A pattern of illegal drug use means more than one
incident of any use of illegal drugs during the previous DHA will consider all credible evidence, including but not
six months. limited to, any record of arrests or convictions of
household members related to the use of illegal drugs.
DHA will consider all credible evidence, including but Arrest records or police reports will not be used as the
not limited to, any record of arrests or convictions of sole basis for terminating a lease. An arrest record or
household members related to the use of illegal drugs. police report may, however, trigger an investigation into
whether the applicant actually engaged in disqualifying
In making its decision to terminate the lease, DHA will criminal activity. A conviction will be given more weight
consider alternatives as described in Section 13-III.D than an arrest.
and other factors as described in Section 13-III.E. Upon
consideration of such alternatives and factors, DHA In making its decision to terminate the lease, DHA will
13-III.B may, on a case-by-case basis, choose not to terminate consider alternatives as described in Section 13-III.D and
the lease. other factors as described in Section 13-III.E. Upon
consideration of such alternatives and factors, DHA may,
on a case-by-case basis, choose not to terminate the lease.
Threat to Other Residents [24 CFR 966.4(l)(5)(ii)(A)] Threat to Other Residents [24 CFR 966.4(l)(5)(ii)(A)]
The lease must provide that any criminal activity by a covered The lease must provide that any criminal activity by a covered
person that threatens the health, safety, or right to peaceful person that threatens the health, safety, or right to peaceful
enjoyment of the premises by other residents (including DHA enjoyment of the premises by other residents (including DHA
management staff residing on the premises) or by persons management staff residing on the premises) or by persons residing
residing in the immediate vicinity of the premises is grounds in the immediate vicinity of the premises is grounds for
for termination of tenancy. termination of tenancy.
DHA Policy DHA Policy
DHA will terminate the lease when a covered person DHA will terminate the lease when a covered person
engages in any criminal activity that threatens the engages in any criminal activity that threatens the health,
health, safety, or right to peaceful enjoyment of the safety, or right to peaceful enjoyment of the premises by
premises by other residents (including DHA other residents (including DHA management staff residing
management staff residing on the premises) or by
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persons residing in the immediate vicinity of the on the premises) or by persons residing in the immediate
premises. vicinity of the premises.
Immediate vicinity means within a three-block radius Immediate vicinity means within a three-block radius of
of the premises. the premises.
DHA will consider all credible evidence, including but DHA will consider all credible evidence, including but not
not limited to, any record of arrests or convictions of limited to, any record of arrests or convictions of covered
covered persons related to the criminal activity. persons related to the criminal activity. Arrest records or
police reports will not be used as the sole basis for
In making its decision to terminate the lease, DHA will terminating a lease. An arrest record or police report
consider alternatives as described in Section 14-III.D may, however, trigger an investigation into whether the
and other factors as described in Section 14-III.E. Upon applicant actually engaged in disqualifying criminal
consideration of such alternatives and factors, DHA activity. A conviction will be given more weight than an
may, on a case-by-case basis, choose not to terminate arrest.
the lease.
In making its decision to terminate the lease, DHA will
consider alternatives as described in Section 14-III.D and
other factors as described in Section 14-III.E. Upon
consideration of such alternatives and factors, DHA may,
on a case-by-case basis, choose not to terminate the lease.
Alcohol Abuse [24 CFR 966.4(l)(5)(vi)(A)]
DHA must establish standards that allow termination of Alcohol Abuse [24 CFR 966.4(l)(5)(vi)(A)]
tenancy if DHA determines that a household member has DHA must establish standards that allow termination of tenancy if
engaged in abuse or pattern of abuse of alcohol that threatens DHA determines that a household member has engaged in abuse
the health, safety, or right to peaceful enjoyment of the or pattern of abuse of alcohol that threatens the health, safety, or
premises by other residents. right to peaceful enjoyment of the premises by other residents.
DHA Policy DHA Policy
DHA will terminate the lease if DHA determines that a DHA will terminate the lease if DHA determines that a
household member has engaged in abuse or a pattern household member has engaged in abuse or a pattern of
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of abuse of alcohol that threatens the health, safety, abuse of alcohol that threatens the health, safety, or right
or right to peaceful enjoyment of the premises by to peaceful enjoyment of the premises by other residents.
other residents.
A pattern of such alcohol abuse means more than one
A pattern of such alcohol abuse means more than one incident of any such abuse of alcohol during the previous
incident of any such abuse of alcohol during the six months.
previous six months.
DHA will consider all credible evidence, including but not
DHA will consider all credible evidence, including but limited to, any record of arrests or convictions of
not limited to, any record of arrests or convictions of household members related to the abuse of alcohol.
household members related to the abuse of alcohol. Arrest records or police reports will not be used as the
sole basis for terminating a lease. An arrest record or
police report may, however, trigger an investigation into
whether the applicant actually engaged in disqualifying
criminal activity. A conviction will be given more weight
than an arrest.
Furnishing False or Misleading Information Concerning Illegal Furnishing False or Misleading Information Concerning Illegal
Drug Use or Alcohol Abuse or Rehabilitation [24 CFR Drug Use or Alcohol Abuse or Rehabilitation [24 CFR
966.4(l)(5)(vi)(B)] 966.4(l)(5)(vi)(B)]
DHA must establish standards that allow termination of DHA must establish standards that allow termination of tenancy if
tenancy if DHA determines that a household member has DHA determines that a household member has furnished false or
furnished false or misleading information concerning illegal misleading information concerning illegal drug use, alcohol abuse,
drug use, alcohol abuse, or rehabilitation of illegal drug users or rehabilitation of illegal drug users or alcohol abusers.
or alcohol abusers.
DHA Policy
DHA Policy DHA will terminate the lease if DHA determines that a
DHA will terminate the lease if DHA determines that a household member has furnished false or misleading
household member has furnished false or misleading information concerning illegal drug use, alcohol abuse, or
information concerning illegal drug use, alcohol abuse, rehabilitation of illegal drug users or alcohol abusers.
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or rehabilitation of illegal drug users or alcohol
abusers. DHA will consider all credible evidence, including but not
limited to, any record of arrests or convictions of
DHA will consider all credible evidence, including but not household members related to the use of illegal drugs or
limited to, any record of arrests or convictions of household the abuse of alcohol, and any records or other
members related to the use of illegal drugs or the abuse of documentation (or lack of records or documentation)
alcohol, and any records or other documentation (or lack of supporting claims of rehabilitation of illegal drug users or
records or documentation) supporting claims of rehabilitation alcohol abusers. Arrest records or police reports will not
of illegal drug users or alcohol abusers. be used as the sole basis for terminating a lease. An
arrest record or police report may, however, trigger an
investigation into whether the applicant actually
engaged in disqualifying criminal activity. A conviction
will be given more weight than an arrest.
13-III.C. OTHER AUTHORIZED REASONS FOR TERMINATION 13-III.C. OTHER AUTHORIZED REASONS FOR TERMINATION [24
[24 CFR 966.4(l)(2) and (5)(ii)(B)] CFR 966.4(l)(2) and (5)(ii)(B)]
Over-Income Families [24 CFR 960.261 and FR 11/26/04, p. Over-Income Families [HOTMA Sec. 103, FR 7/26/18, P.35490-
68786] 35494, 24 CFR 960.261 and FR 11/26/04, p. 68786]
Subject to certain restrictions, HUD authorizes PHA’s to evict The Housing Opportunity Through Modernization Act (HOTMA)
or terminate the tenancies of families because they are over of 2016 places an income limitation on public housing tenancy for
income. Unless required to do so by local law, DHA may not families. The law requires that once a family’s income has
13-III.C
evict or terminate the tenancy of a family solely because the exceeded 120% of AMI, or a different limitation set by the
family is over income if: (1) the family has a valid contract of Secretary of HUD (“over-income limit”) for two consecutive
participation in the Family Self-Sufficiency (FSS) program, or years, DHA must terminate the family’s tenancy within six (6)
(2) the family is currently receiving the earned income months of the second income determination or charge the family
disallowance. This rule does not require PHA’s to evict over- a monthly rent equal to the greater of:
income residents, but rather gives PHA’s the discretion to do (1) The applicable Fair Market Rent (FMR) for the area; or
so thereby making units available for applicants who are (2) The amount of monthly subsidy for the unit including
income-eligible. amounts from the operating and capital fund, as
DHA Policy determined by regulations.
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DHA will not evict or terminate the tenancies of families solely DHA must notify a family of the potential changes to monthly
because they are over income. rent or potential termination after one (1) year of the family’s
income exceeding the over-income limit.
DHA must submit a publicly available report to HUD annually
about the number of families residing in public housing with
incomes exceeding the over-income limit and the number of
families on the waiting lists for admission to public housing.
Subject to certain restrictions, HUD authorizes PHA’s to evict or
terminate the tenancies of families because they are over
income. Unless required to do so by local law, DHA may not evict
or terminate the tenancy of a family solely because the family is
over income if: (1) the family has a valid contract of participation
in the Family Self-Sufficiency (FSS) program, or (2) the family is
currently receiving the earned income disallowance. This rule does
not require PHA’s to evict over-income residents, but rather gives
PHA’s the discretion to do so thereby making units available for
applicants who are income-eligible.
DHA Policy
DHA will not evict or terminate the tenancies of families solely
because they are over income; however, DHA will consider the
number of families on the waiting lists for admission when
making a determination regarding whether to terminate a family
whose income exceeds the over-income limit.
13-III.E. CRITERIA FOR DECIDING TO TERMINATE TENANCY 13-III.E. CRITERIA FOR DECIDING TO TERMINATE TENANCY
13-III.E A DHA that has grounds to terminate a tenancy is not required A DHA that has grounds to terminate a tenancy is not required to
to do so, except as explained in Part II of this chapter, and may do so, except as explained in Part II of this chapter, and may
consider all of the circumstances relevant to a particular case consider all of the circumstances relevant to a particular case
before making a decision. before making a decision.
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Evidence [24 CFR 982.553(c)] Evidence [24 CFR 982.553(c)]
For criminal activity, HUD permits DHA to terminate the lease For criminal activity, HUD permits DHA to terminate the lease if a
if a preponderance of the evidence indicates that a household preponderance of the evidence indicates that a household member
member has engaged in the activity, regardless of whether the has engaged in the activity, regardless of whether the household
household member has been arrested or convicted, and member has been arrested or convicted, and without satisfying the
without satisfying the standard of proof used for a criminal standard of proof used for a criminal conviction.
conviction. DHA Policy
DHA Policy DHA will use the concept of the preponderance of the
DHA will use the concept of the preponderance of the evidence as the standard for making all termination
evidence as the standard for making all termination decisions.
decisions. Preponderance of the evidence is defined as evidence which is of
Preponderance of the evidence is defined as evidence which is greater weight or more convincing than the evidence which is
of greater weight or more convincing than the evidence which offered in opposition to it; that is, evidence which as a whole
is offered in opposition to it; that is, evidence which as a whole shows that the fact sought to be proved is more probable than not.
shows that the fact sought to be proved is more probable than Preponderance of the evidence may not be determined by the
not. Preponderance of the evidence may not be determined number of witnesses, but by the greater weight of all evidence.
by the number of witnesses, but by the greater weight of all
evidence. Consideration of Circumstances [24 CFR 966.4(l)(5)(vii)(B)]
Although it is required that certain lease provisions exist for
Consideration of Circumstances [24 CFR 966.4(l)(5)(vii)(B)] criminal activity and alcohol abuse, HUD provides that DHA may
Although it is required that certain lease provisions exist for consider all circumstances relevant to a particular case in order to
criminal activity and alcohol abuse, HUD provides that DHA determine whether or not to terminate the lease.
may consider all circumstances relevant to a particular case in
order to determine whether or not to terminate the lease. Such relevant circumstances can also be considered when
terminating the lease for any other reason.
Such relevant circumstances can also be considered when
13-III.E. terminating the lease for any other reason. A resident who fails to pay rent when due which results in DHA
filing court papers two times in a 12 month period prior to issuance
A resident who fails to pay rent when due which results in DHA of a termination letter, shall be required to participate in the DHA
filing court papers two times in a 12 month period prior to Resident Services Money Management Program, and upon
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issuance of a termination letter, shall be required to successful completion will have the first infraction of nonpayment
participate in the DHA Resident Services Money Management forgiven, and the 12 month period will begin on the date of the
Program, and upon successful completion will have the first second filing. This option shall be given only once during tenancy.
infraction of nonpayment forgiven, and the 12 month period
will begin on the date of the second filing. This option shall be DHA Policy
given only once during tenancy. DHA will consider the following factors before deciding
whether to terminate the lease for any of the HUD
DHA Policy required lease provisions or for any other reasons:
DHA will consider the following factors before The seriousness of the offending action, especially
deciding whether to terminate the lease for any of the with respect to how it would affect other residents
HUD required lease provisions or for any other The extent of participation or culpability of the
reasons: leaseholder, or other household members, in the
The seriousness of the offending action, offending action, including whether the culpable
especially with respect to how it would affect member is a minor or a person with disabilities
other residents The effects that the eviction will have on other
The extent of participation or culpability of the family members who were not involved in the
leaseholder, or other household members, in action or failure to act
the offending action, including whether the The effect on the community of the termination, or
culpable member is a minor or a person with of DHA’s failure to terminate the tenancy
disabilities The effect of DHA’s decision on the integrity of the
The effects that the eviction will have on other public housing program
family members who were not involved in the The demand for housing by eligible families who will
action or failure to act adhere to lease responsibilities
The effect on the community of the The extent to which the leaseholder has shown
termination, or of DHA’s failure to terminate personal responsibility and whether they have
13-III.E. the tenancy taken all reasonable steps to prevent or mitigate the
The effect of DHA’s decision on the integrity of offending action
the public housing program The length of time since the violation occurred, the
The demand for housing by eligible families who family’s recent history, and the likelihood of
will adhere to lease responsibilities favorable conduct in the future
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