PHA PLAN THE HOUSING AUTHORITY OF BERGEN COUNTY - Bergen County Housing Authority

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PHA PLAN THE HOUSING AUTHORITY OF BERGEN COUNTY - Bergen County Housing Authority
THE HOUSING AUTHORITY OF BERGEN COUNTY

PHA PLAN
FISCAL YEAR 04/2020

5 YEAR AND ANNUAL PLAN
PHA PLAN THE HOUSING AUTHORITY OF BERGEN COUNTY - Bergen County Housing Authority
04/2020 PHA PLAN

Table of Contents
EXECUTIVE SUMMARY ................................................................................................................................. 3
Five-Year PHA Plan ........................................................................................................................................ 4
   MISSION .................................................................................................................................................... 4
   PROGRESS ................................................................................................................................................ 4
       Developments ........................................................................................................................................ 4
       Section 8 Housing Choice Voucher ......................................................................................................... 5
       CoC Grants ............................................................................................................................................. 5
       RAD........................................................................................................................................................ 5
   GOALS ....................................................................................................................................................... 5
   FINANCIAL RESOURCES ........................................................................................................................... 6
ANNUAL PHA PLAN ...................................................................................................................................... 7
   HOUSING NEEDS ...................................................................................................................................... 7
       CURRENT PROGRAM STATISTICS ........................................................................................................ 7
       HOUSING NEED ASSESSMENT ........................................................................................................... 10
       PHA STRATEGY AND POLICIES ........................................................................................................... 10
   FINANCIAL RESOURCES ......................................................................................................................... 12
   RENT DETERMINATION POLICIES .......................................................................................................... 12
   OPERATION AND MANAGEMENT ...........................................................................................................13
       PHA management organization ............................................................................................................13
       List of Programs and Buildings ............................................................................................................. 14
   PHA INFORMAL HEARING AND REVIEW PROCEDURES ........................................................................ 15
   COMMUNITY SERVICE AND SELF-SUFFICIENCY PROGRAMS ............................................................... 16
   FISCAL AUDIT .......................................................................................................................................... 16
References .................................................................................................................................................... 17

ATTACHMENTS

      A.    Form HUD – 50077-SL
      B.    Form HUD - 50077-CR
      C.    Form HUD - 50077-ST-HCV-HP
      D.    Form HUD – 50075-5Y

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PHA PLAN THE HOUSING AUTHORITY OF BERGEN COUNTY - Bergen County Housing Authority
04/2020 PHA PLAN

EXECUTIVE SUMMARY

The Housing Authority of Bergen County’s (HABC) streamlined Five-Year and Annual PHA Plan for fiscal
year beginning April 1, 2020 outlines how the HABC will prioritize and target the federal assistance received
by the Authority. All federal funds are utilized to meet our mission of Creating and Preserving Affordable
Housing, positively impact the 4,000 families we serve through a multitude of programs, as well as serving
homeless families in Bergen County by creating avenues for self-sufficiency.

Additionally, the HABC’s non-profit real estate development arm, the Housing Development Corporation of
Bergen County (HDC), will continue to develop affordable housing. The HDC will assist by applying for
federal and local funding sources as available to create new affordable units, will partner with local
municipalities to assist in meeting their affordable housing requirements, and partner with other non-profit
developers and service provider where possible to create new affordable permanent housing units with
supportive services for targeted low-income populations.

Major initiatives for the 2020-2025 period include:

    •   HDC development of Low-income Family units in Closter, NJ
    •   HDC development of Low-income Special Needs and Veteran units in East Rutherford, NJ
    •   HDC development of Low-income Senior units in Fort Lee, NJ
    •   HDC development of Low-income Senior units in North Arlington, NJ
    •   HDC development of Low-income Senior and Special Needs units in Upper Saddle River, NJ
    •   HDC development of Low-income Family units in Woodcliff Lake, NJ
    •   HABC will also look to expand and explore new opportunities to partner with other community
        agencies in housing opportunities for targeted populations.
    •   HABC will provide permanent housing solutions for homeless households
    •   HABC will provide homelessness prevention assistance for households at-risk of homelessness
    •   HABC will provide rental assistance to the applicants on the HCV wait list
    •   HABC proposes to open the HCV wait list to new applicants at least once in the 5-year period

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Five-Year PHA Plan
MISSION
The HABC’s mission is to provide, sustain, and expand opportunities for extremely low-income to low-
income families. The HABC has initiatives to develop new rental units, expand initiatives to work with other
agencies in housing targeted populations and other vulnerable populations.

The HABC will look to maximize HUD funds in providing housing opportunities through the Housing Choice
Voucher (HCV) program, HCV Project Based Voucher program and continue to utilize our non-profit real
estate development arm, the Housing Development Corporation of Bergen County (HDC), in developing and
preserving affordable housing. In addition, the HABC will continue to pursue all available subsidies and
resources, federally and locally, to accomplish our mission.

The HABC as the contracted manager of the Bergen County Housing, Health and Human Services Center
(BCHHH), the County’s 90 bed emergency shelter. The BCHHH serves as a one-stop location and single
point of entry for individuals to receive information, care management, meals, health and human services,
and financial assistance. In this capacity, the HABC serves and assists the lowest income and most
vulnerable households in the County through intake, assessment and placement on the countywide
Vulnerability Index – Service Prioritization Decision Assistance Tool “Bergen County Coordinated
Assessment list” and houses those on the list in accordance with our resources.

The HABC has an Emergency Transfer Plan for victims of domestic violence and all policies and procedures
reflect this commitment. Our goals are to bring awareness to our clients and residents on their rights and
options. To create an environment where clients feel safe and secure in reporting domestic violence and
seeking guidance on housing options from well trained staff. The HABC has worked successfully with the
Center for Hope and Safety, a non-profit organization dedicated to assisting victims and their children of
domestic violence, in housing homeless families, prioritizing and housing victims as well as educating staff
and clients.

PROGRESS
Developments
In the last 10 years the HABC/HDC have constructed 78 new affordable housing units of which 31 were for
homeless individuals or families. The approximately $8 million in construction funding is largely public
funding and resources utilized to create these units.

Over the last five years the HABC has completed development and lease up the following projects:

    1.   Saddle Brook Senior Housing – 24 senior housing and 6 special needs non-age restricted;
    2.   Emerson Veterans Supportive Housing – 14 units homeless disabled vets;
    3.   Franklin Villa Apartments – 21 senior and 8 homeless veteran units;
    4.   River Vale Senior Housing – 49 senior units;
    5.   Martin Luther King Jr. Senior Center & Apartments – 4 special needs units and

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Section 8 Housing Choice Voucher
In the past year the HABC has maximized vouchers utilization in the Housing Choice Voucher program,
balancing per unit costs, lease up timeframes and wait list management. Further, the HABC was able to
open our Section 8 Housing Choice Voucher waiting list for the first time in a decade.

Within the last five years we have assisted 187 homeless families through the HCV program through referrals
from Bergen County’s Coordinated Assessment List of which 41 have been Domestic Violence victims.

We have implemented Small Area Fair Market Rents (SAFMR) furthering national deconcentration goals.
We are a metropolitan area considered a suburb of Manhattan with a vast array of neighborhoods and
communities and 72 zip codes; the implementation of SAFMR allows us to accommodate the rental costs in
these varying neighborhoods providing greater choice in mobility.

The HABC applied for and was awarded 35 Mainstream vouchers in November of 2018. Mainstream
vouchers are non-elderly and disabled households who are homeless, at risk of homelessness, transitioning
out of institutionalization or at risk of institutionalization. We partnered with the I Choose Home New Jersey
Program (ICHNJ) under the NJ Office of Long-Term Care Ombudsman Office to target households who are
transitioning out of an institution.

CoC Grants
Within the past ten years the HABC has been awarded over $3.3 million in Emergency Solutions Grant which
have been utilized to provide short term assistance to 393 households.

We have coordinated efforts with the Bergen County Continuum of Care to assist the most vulnerable
households utilizing Bergen County’s Coordinated Assessment List. Through this coordinated effort the
HABC has received five grants that are renewed annually, receiving $6,908,884 in rental assistance funding
for targeted households. We have assisted 155 families, 9 having transitioned to more permanent housing
programs without supportive service requirements and remain permanently housed.

RAD
The HABC converted our entire portfolio of public housing units through the Rental Assistance
Demonstration (RAD) opportunity. The conversion of 498 units was completed in December of 2016.

GOALS
The HABC goals and objectives for the next five years are consistent with our overall mission and we will
continue to serve income eligible populations and target the most vulnerable in our community. As the
needs of our community are met and change our targets will evolve. The HABC will continue our partnership
with the Bergen County Continuum of Care to facilitating a first model, ensuring the successful housing of
homeless households and those at risk of homelessness, and continuing to utilize and improve upon the use
of the Coordinated Assessment List.

The HABC will measure the success of our policies and procedures with the continuous review of our data,
improvement of our date collection and analysis to strategically target investments and resources for the
greatest success.

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     FINANCIAL RESOURCES
                              PHA Financial Resources 5 Year Plan
                                     CY 2020           CY 2021         CY 2022          CY 2023         CY 2024
1     Federal Grants
      Annual Contributions
    a for HCV/Section 8
              HCV Section 8      $ 40,623,510      $ 41,435,980    $ 42,264,699     $ 43,109,994    $ 43,972,194
                    Program
         Administration Fees     $ 3,666,514       $ 3,739,844     $ 3,814,641      $ 3,890,934     $ 3,968,752
              RAD PBV HAP        $ 2,191,392       $ 2,235,220     $ 2,279,924      $ 2,325,523     $ 2,372,033
      Emergency Solutions
    b Grant                      $     436,295     $     445,021   $     453,921    $     463,000   $     472,260
      Home Investments
    c Partnership                $     350,000     $     350,000   $     350,000    $     350,000   $     350,000
      Continuum of Care
    d Program                    $ 1,849,426       $ 1,914,156     $    1,981,151   $ 2,050,492     $ 2,122,259
      Section 8 Mainstream
    e Vouchers                   $     463,059     $     470,005   $     477,055    $     484,211   $     491,474

       Prior Year Federal
2      Grants (unobligated)      $             -

       RAD Development
       Dwelling Rental
3      Income                    $ 1,761,132       $ 1,796,355     $ 1,832,282      $ 1,868,927     $ 1,906,306

4      Other Income
                  HOPWA          $    437,798      $   437,798     $      437,798   $   437,798     $    437,798
           Management Fees       $ 1,069,625       $ 1,123,106     $    1,179,262   $ 1,238,225     $ 1,300,136

5      Non-Federal Sources:
       County Funds - HHH
       Center                    $     705,471     $     792,870   $     847,971    $     907,329   $     970,842
       County Funds - MLK
       Senior Center             $    106,728      $    106,728    $     106,728    $     106,728   $    106,728
       State Funds               $    260,000      $    260,000    $     260,000    $     260,000   $    260,000

       Total Resources           $ 53,920,950      $ 55,107,082    $ 56,285,432     $ 57,493,160    $ 58,730,781
                                                           2.2%           2.1%             2.1%            2.2%

     Note: All the above were budgeted based on the following assumptions. 1) HCV programs assumed 2%inflation
     factor. 2) RAD assumed 1.5% inflation factor. 3) ESG assumed 2% increase. 4) HOPWA, TBRA, NJEA and MLK
     Grant were left flat. 5) CoC grants assumed 3.5% increase.

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ANNUAL PHA PLAN
HOUSING NEEDS
The HABC currently provides rental assistance to 3,467 families through our Section 8 Housing Choice
Voucher program. The number of households fluctuates throughout the year, due to family self-sufficiency,
portability and termination. The HCV wait list is presently 353 applicants. The program wait list last opened
in 2019. In addition, we maintain a wait list for each of our PBV projects and individual wait lists for all HABC
operated buildings. A breakdown of all HABC tenant-based assistance and affordable units can be found on
page 14.

CURRENT PROGRAM STATISTICS
Statistics are for HCV program including (NED, Mainstream and PBV projects).

    •   Head of Households

                                                    Gender

                                                         23%

                                                                                                    Male
                                                                                                    Female

                                            77%

                            Handicapped/Disabled or Elderly

                                                  45%                          Handicapped/Disabled/Elderly
                               55%                                             Other

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                                                   Ethicity

                                                      30%
                                                                                                   Hispanic
                                                                                                   Non-Hispanic
                                       70%

                                                     Race

                            27%
                                              4%                             Caucasian
                                                                             African American
                                              3%
                                                                             Multi-racial
                                                                     4%
                                              4%
                                                                             Native Hawaiian/Other Pacific Island
                                                                             Asian
                    62%                                                      American Indian/Alaska Native
                                                                     0%

   •   Total Annual Income (HUD’s FY2017 Median Income for Bergen County is $96,500)
                             Low
                             3%         Household Income
                                                   Moderate - High
                                   Very Low             0%
                                     16%

                                                                 Extremely low
                                                                      81%

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    •   Bedroom Sizes (Units leased)

                                                Bedrooms
                                               2% 0%

                                                    3%
                                         14%
                                                                                              0 Bedroom
                                                                                              1 Bedroom

                                                                          51%                 2 Bedroom
                            30%
                                                                                              3 Bedroom
                                                                                              4 Bedroom
                                                                                              5+ Bedroom

    •   Total households with Dependents and total households with Medical Expenses

                                   Dependents and Medical
           35%
                                         35%
           30%

           25%

           20%                                                             18%

           15%

           10%

            5%

            0%
                      HOUSEHOLDS WITH DEPENDENTS               HOUSEHOLDS WITH MEDICAL EXPENSES

The HABC utilized information available on the United States Census Bureau website to obtain the following
statistical information regarding Bergen County. This information is based on the 2010 Census of Population
and Population Estimates updated July 1, 2018.

The current report estimates that the population for Bergen County is 936,692 and there are 359,291
housing units in the county of which 64.6% are owner-occupied. Therefore, we can estimate that 35% of the
housing market is open to renters. The median gross rent estimated between 2013 and 2017 is $1,419. In
addition, estimates show that the population of Bergen County has decreased 3.5% from 2010 to 2018.

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The number of persons age 65 and older is estimated to have increased from 16.5% to 17.2% for the 2018
estimate compared to the 2016 estimate. The number of disabled persons under the age of 65 is estimated
at 4.3% from 2013-2017.

The female population of Bergen County has held steady at around 52%. The percentage of Hispanic
persons is estimated to have increased from 19.4% in 2016 to 20.6% in 2018.

                                    Race Estimates for 2018
                                    0%   2%                           White

                                                                      Black or African American
                              17%
                    1%                                                American Indian and Alaska Native
                         7%
                                                                      Asian

                                              73%
                                                                      Native Hawaiian and Other Pacific
                                                                      Islander
                                                                      Two or More Races

The median household income in 2017 was $91,572. The US Census estimates that 6.6% of the Bergen
County population is in poverty which is approximately 61,822 persons based on the current 2016 population
estimates. This estimate is down from 7.1% in 2016.

HOUSING NEED ASSESSMENT
The data collection exemplifies the need for rental assistance expansion in Bergen County. The population
of Bergen County is increasing, the demand for rental units is also increasing with only 64.6% of housing
being owner-occupied. The development of new housing stock has substantially slowed with only 2,849
permits requested. Bergen County remains one of the least affordable areas to live in the country but
maintains a steady increase in housing cost. Additionally, the need for affordable housing continues as the
population grows older. The largest portion of the participants on the program are disabled and elderly
compared to the makeup of the County population. Much of this population have Extremely Low-Incomes
and half of the program reside in one-bedroom units.

Our assessment of housing needs correlates with the State of New Jersey 2015-2019 Consolidated Plan and
the County of Bergen New Jersey 2015-2019 Consolidated Plan. The Consolidated Plan will be updated for
August of 2020. Overcrowding occurs as the contract rents increase to match cost-of-living increases. A
significant portion of our population still experience housing burdens of more than fifty percent of their
income. In addition, there is a significant number of single person households who cycle through emergency
shelter or transitional housing.

PHA STRATEGY AND POLICIES
The HABC provides preference for homeless households. Homeless families that are residents of Bergen
County can be added to the wait list at any time and will remain on the wait list if added at any time after the

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list has been closed so long as they continue to meet the criteria of the homeless definition. The HABC also
provides preference for families whose head, co-head or spouse are seniors, disabled, working, or going to
school in addition to a County resident preference.

The HABC will continue to review and adjust payment standards to balance the funding provided and the
needs of County population with the consideration of the housing market. The County’s jurisdiction makes
up an array of communities that vary in housing cost and household median income.

The HABC implemented Small Area Fair Market Rents which is intended to create affordability in
communities that may not have not been affordable to applicants and participants due to higher housing
costs. The HABC’s goal is to improve housing mobility and will collect data and information on our
municipalities to share with our participants and applicants. Collection of information is intended to provide
useful information that will assist our clients in moving to areas of greater opportunity within our
jurisdiction.

The HABC will also continue to provide project based assistance to developments for target populations
such as seniors and disabled throughout the County. The HABC will maintain site-based waiting lists for all
Project Based Developments and RAD Developments.

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FINANCIAL RESOURCES
The financial resources that are anticipated to be available to the PHA for the support of Federal tenant-
based Section 8 Housing Choice Voucher assistance programs administered by the PHA during the plan year
are outlined below.

                     CY 2020 PHA Annual Plan
 1     Federal Grants
     a Annual Contributions for HCV/Section 8
                                          HCV Section 8        $   40,623,510
                           Program Administration Fees         $    3,666,514
                                         RAD PBV HAP           $    2,191,392
     b Emergency Solutions Grant                               $      436,295
     c Home Investments Partnership                            $      350,000
     d Continuum of Care Program                               $    1,849,426
     e Section 8 Mainstream Vouchers                           $      463,059

 2      Prior Year Federal Grants (unobligated)                $             -

 3      RAD Development Dwelling Rental Income                 $    1,761,132

 4      Other Income
                                                HOPWA          $    437,798
                                         Management Fees       $ 1,069,625

 5      Non-Federal Sources:
        County Funds - HHH Center                              $      705,471
        County Funds - MLK Senior Center                       $     106,728
        State Funds                                            $     260,000

        Total Resources                                        $ 53,920,950

RENT DETERMINATION POLICIES
Participants of the Tenant Based Rental Assistance Program and Project Based Rental Assistance programs
contribute a minimum of thirty percent of their adjusted annual income or ten percent of their gross
monthly income, whichever is greater, towards the rent. The HABC also implements a minimum rent of
$50.00 however families can apply for an exception to the minimum rent due to a hardship.

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OPERATION AND MANAGEMENT
PHA management organization
The present HABC Organizational Chart below is below.

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List of Programs and Buildings
 Grants and Programs                           No. leased          Voucher Allotment
 Housing Choice Voucher                        2997                3,586 (total HCVs)
      • Non-Elderly Disabled (NED)             172                 175
      • Mainstream                             26                  35
 Continuum of Care (CoC)                       77                  90
          • CoC – Sponsor-based                21                  22
          • CoC – Project-based                8                   8
 TBRA – HOME program                           26                  35
 HOPWA                                         33                  37
 Rental Assistance Demonstration (RAD)         No. of Units        Location
 Boiling Springs (RAD)                         142                 East Rutherford, NJ
 Carucci (RAD)                                 98                  Lyndhurst, NJ
 David F. Roche (RAD)                          99                  Dumont, NJ
 Highland View (RAD)                           94                  Palisades Park, NJ
 Mahwah (RAD)                                  54                  Mahwah, NJ
 Ramsey (RAD)                                  11                  Ramsey, NJ
 Project-Based Vouchers (PBV)                  No. of Units        Location
                             Housing Development Corp. (HDC) owned
 Emerson Veterans                              14                  Emerson, NJ
 Fairview Gardens                              9                   Fairview, NJ
 Hasbrouck Heights                             31                  Hasbrouck Heights, NJ
 Northvale                                     21                  Northvale, NJ
 Northvale Senior Residence (LIHTC)            29                  Northvale, NJ
 Old Tappan                                    29                  Old Tappan, NJ
 Saddle Brook Senior Housing                   30                  Saddle Brook, NJ
 Saddle River                                  18                  Saddle River, NJ
 Silver Maple Gardens                          20                  Bogota, NJ
                                            HABC owned
 MLK Senior Center                             4                   Hackensack, NJ
                                     Private / Non-profit owned
 The Heritage                                  45                  Lyndhurst, NJ
 Montvale Commons                              10                  Montvale, NJ
 Multi-family Section 202 units                No. of Units        Location
 River Vale Senior Residence (Tax credit)      49                  River Vale, NJ
 Brookside Gardens                             134                 Bergenfield, NJ
 Ridge Crest Apts                              129                 Ridgewood, NJ
 Lehmann Gardens                               35                  Park Ridge, NJ
 LIHTC                                         No. of Units        Location
 Grove St (Tax credit)                         25                  S. Hackensack, NJ
 COAH                                          No. of Units        Location
 Garden House                                  2                   East Rutherford, NJ
 Edgewater                                     3                   Edgewater, NJ
 Montvale Condos                               2                   Montvale, NJ
 HABC MANAGED                                  No. of Units        Location
 Teterboro                                     18                  Teterboro, NJ

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PHA INFORMAL HEARING AND REVIEW PROCEDURES
The HABC offers applicants and participants the opportunity to dispute a decision made by the HABC that
has a negative impact on the family. For applicants, the appeal takes the form of an informal review; for
participants, the appeal takes the form of an informal hearing. Decisions subject to an informal review
should an applicant request include the following:

    •   Denying listing on the wait list;
    •   Denying or withdrawing a voucher;
    •   Refusing to enter into a HAP contract or approve a lease;
    •   Refusing to process or provide assistance under portability procedures.

Decisions subject to an informal hearing should a participant request include the following:

    •   A determination of the family’s annual or adjusted income, and the use of such income to compute
        the housing assistance payment;
    •   A determination of the appropriate utility allowance (if any) for tenant-paid utilities from the HABC
        utility allowance schedule;
    •   A determination of the family unit size under the HABC’s subsidy standards;
    •   A determination to terminate assistance for a participant family because of the family’s actions or
        failure to act;
    •   A determination to terminate assistance because the participant has been absent from the assisted
        unit for longer than the maximum period permitted under HABC policy and HUD rules;
    •   A determination to terminate a family’s Family Self Sufficiency contract, withhold supportive
        services, or propose forfeiture of the family’s escrow account [24 CFR 984.303(i)].

Where Public Housing units have been converted to PBV under RAD the regulation additionally stipulates
that:

    a) An opportunity for an informal hearing be given for any dispute that a resident may have with
       respect to a PHA (as owner) action in accordance with the individual’s lease or the contract
       administrator in accordance with RAD PBV requirements that adversely affect the resident’s rights,
       obligations, welfare, or status.
    b) An informal hearing will not be required for class grievances or to disputes between residents not
       involving the PHA (as owner) or contract administrator. This hearing requirement is not intended
       and shall not apply as a forum for initiating or negotiating policy changes between a group or groups
       of residents and the PHA (as owner).
    c) The PHA (as owner) will provide the opportunity for an informal hearing before an eviction.

A request for an informal review must be made in writing and delivered to the HABC either in person or by
first class mail, by the close of the business day, no later than 10 business days from the date of the HABC’s
notice of denial of assistance. If the family does not appear at the scheduled time and was unable to
reschedule the hearing in advance due to the nature of the conflict, the family must contact the HABC within
24 hours of the scheduled hearing date, excluding weekends and holidays. The HABC will reschedule the
hearing only if the family can show good cause for the failure to appear, or if it is needed as a reasonable

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accommodation for a person with disabilities. After failure to attend two scheduled hearings, the family will
not be given another opportunity for a hearing and the HABC’s original decision will stand.

If the HABC, with good effort, was not able to hold a hearing within 45 days from the date of request due to
the families delay or those working on behalf of the family, the HABC will cease HAP payments until such
time the informal hearing is held. If a hearing decision results in reinstatement of the family to the program
the assistance will resume beginning the date of the Hearing Officer’s Determination and notification.

COMMUNITY SERVICE AND SELF-SUFFICIENCY PROGRAMS
If a family is living in a project-based unit that is excluded from the 25 percent per project cap on project-
basing because of participation in a supportive services program (e.g., Family Self-Sufficiency), and the
family fails to complete its supportive services requirement without good cause, such failure is grounds for
lease termination by the owner.

FISCAL AUDIT
The HABC most recent audit for fiscal year ending March 31, 2019 conducted by an independent auditor
found that the HABC must improve internal controls to ensure the proper collection and cataloging of
required documents for the Section 8 Housing Choice Voucher Program. In addition, the HABC must
improve internal control procedures that have oversight of the implementation of abatements.

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References
The 2015-2019 Consolidated Plan of State of New Jersey by the Department of Community Affairs was used
in assessment and development of the HABC PHA Plans.

The HABC utilized information available on the United States Census Bureau website.

The County of Bergen New Jersey Consolidated Plan FY 2015-2019 by the County Executive Office of Bergen
County was used in assessment and development of the HABC PHA Plans.

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