§ 4-71Establishment of program.
§ 4-72Scope of program and services.
§ 4-73Participant selection.
§ 4-74Contract of participation.
§ 4-75Other program information.
The WHA operates a Family Self-Sufficiency (FSS) Program to support residents' efforts toward self- sufficiency by identifying and removing the barriers that are keeping participating families dependent on the public assistance system.
Purpose.
The purpose of the FSS Program is to promote the development of local strategies to coordinate the use of public housing assistance and housing assistance under the housing choice voucher programs with public and private resources to enable families eligible to receive assistance under these programs to achieve economic independence and self-sufficiency.
The FSS Program is administered in accordance with 24 CFR 984, the WHA's FSS Program Action Plan, the Housing Choice Voucher Program Administrative Plan, and this Admissions and Continued Occupancy Policy.
Program objective.
The objective of the FSS Program is to reduce the dependency of low-income families on welfare assistance and on Section 8, public, or any federal, state, or local rent or homeownership subsidies. Under the FSS Program, low-income families are provided opportunities for education, job training, counseling, and other forms of social service assistance while living in assisted housing, so that they may obtain the education, employment, and business and social skills necessary to achieve self-sufficiency. Self-sufficiency means that an FSS family is no longer receiving Section 8, public or Indian housing assistance, or any federal, state, or local rent or homeownership subsidies or welfare assistance.
Self-sufficiency means than an FSS family is no longer receiving welfare assistance. Welfare assistance, as defined by HUD for the FSS Program, means income assistance from federal or state welfare programs, and includes only cash maintenance payments designed to meet a family's ongoing basic needs.
The WHA will measure the success of the FSS Program not only by the number of families who achieve self-sufficiency, but also by the number of FSS families who, as a result of participation in the program, have family members who obtain their first job or who obtain higher-paying jobs; no longer need benefits received under one or more welfare programs; obtain a high school diploma or higher education degree; or accomplish similar goals that will assist the family in obtaining economic independence.
Action plan. In accordance with 24 CFR 984.201, the WHA developed a HUD-approved action plan prior to implementation of the FSS Program. The action plan describes the policies and procedures of the WHA for operation of the FSS Program.
Program coordinating committee. Per 24 CFR 984.202, the WHA has established a program coordinating committee (PCC) whose function is to assist the WHA in securing commitments of public and private resources for the operation of the FSS Program.
Operational committee. The WHA has established an FSS operational committee whose function is to assist the Self-Sufficiency Coordinators in the maintenance and operation of the FSS Program.
Program size. The actual size of the program will vary at any particular time, depending on interest in the program, participants' progress, and available resources. Generally, full enrollment in the public housing FSS Program is defined as 35 participating families.
Services.
The scope of services provided to each participating family will vary according to that family's needs and goals. Participating families will complete a needs assessment and work individually with the Self-Sufficiency Coordinator to analyze their barriers to self-sufficiency. At a minimum, the WHA will assess each participating family's needs for basic supportive services, including but not limited to:
| Child care | |
| Remedial education | |
| Education for the completion of high school | |
| Postsecondary education and training | |
| Transportation necessary to receive services | |
| Job training preparation | |
| Substance abuse treatment, counseling, and education | |
| Training in homemaker skills and money management | |
| Food | |
| Clothing | |
| Health care | |
| Homeownership education and/or housing counseling |
The WHA will seek the commitment of public and private resources from the community to meet these needs. Referrals are made to appropriate community public agencies, private organizations and industries, and nonprofit entities.
Escrow account. To encourage participation in the FSS Program, HUD has developed an incentive plan to be offered to eligible families.
Determination of contribution.
The amount to be credited to the family's FSS escrow account is calculated by completion of the FSS Escrow Account Worksheet and is determined by increases in the family's level of earned income. For purposes of the FSS escrow credit calculation, "earned income" is defined as the following:
The full amount before any payroll deductions of wages and salaries, overtime pay, commissions, fees, tips and bonuses, and other compensation for personal services.
The net income from operation of a business or profession as determined by the WHA pursuant to 24 CFR 813.106.
All regular pay, special pay, and allowances of a member of the armed forces (excluding special pay to a family member in the armed forces who is exposed to hostile fire).
The family must report any changes in household income (increase, decrease, or change in the source of income) to the WHA within 10 calendar days of the change. The WHA will determine whether or not an interim rent adjustment is necessary. The family shall comply with all requests of program eligibility.
Each time an interim or annual rent determination is completed, a new worksheet will be completed and adjustments made to the level of credit to the family's escrow account. Failure on the part of the family to report income changes may be grounds for termination of public housing assistance and/or the family's participation in the FSS Program. If the WHA elects not to terminate assistance and/or participation in the FSS Program, any retroactive increases to the family's earned income level shall not be credited to the family's escrow account.
Account management.
Pursuant to federal regulations, all FSS escrow funds will be deposited in a HUD-approved interest-bearing account. The WHA has established a single depository account for FSS account funds for all FSS families and a subsidiary ledger which includes sub-accounts for each family. The investment income for the combined FSS funds is prorated and credited to each family's FSS account based on the balance of each account at the end of the period for which the investment income is prorated.
FSS escrow accounts are subject to all applicable State of Rhode Island laws governing escrow accounts.
The WHA is responsible for providing HUD account documentation and meeting HUD reporting requirements. The WHA also makes periodic reports to the coordinating and operational committees so that plans for additional services are organized and implemented in a timely manner.
Disbursement of FSS escrow accounts.
Completion of contract. The amount in the family's escrow account in excess of any money owed to the WHA by the family (to include any money owed the FSS Emergency Fund) shall be paid to the head of the family when the FSS contract has been completed in accordance with § 4-74C below. This can be done at the expiration of the contract term or prior to that so long as the family has fulfilled its obligations under the contract of participation.
Interim disbursement. At the request of the family and the recommendation of the Self-Sufficiency Coordinator in consultation with the FSS Operational Committee, the WHA may at its sole discretion disburse a portion of the funds from the family's FSS escrow account to the head of the family to be used to assist the family in meeting expenses consistent with the contract. In making this determination, the WHA will consider whether the family has met appropriate interim goals in accordance with its ITSP and the proposed use of the disbursed funds. The WHA may request documentation to substantiate the use of borrowed funds. Moreover, the Executive Director has the final authority regarding such decisions.
Effects of termination of program participation. Termination of FSS Program participation shall result in immediate termination of the contract of participation, and the amounts credited to the family's escrow account shall be forfeited. Such action will be taken only after a reasonable effort is made to enable the family to remain in the program and reasonable amendments to the ITSP have been made to accommodate changing circumstances.
Voluntary program. The FSS Program is a voluntary program available to eligible families who are sincere in their intentions to achieve financial independence for their families. Anyone who does not wish to participate in the FSS Program will not lose their housing assistance because of this decision.
Statement of nondiscrimination. Participation in the FSS Program shall be open to all eligible families, as defined below, subject to availability of FSS slots. Determination of eligibility shall be on a uniform, nondiscriminatory basis in respect to race, color, sex, religion, familial status, disability, or national origin. There will be no discrimination on the basis of level or source of income.
Eligibility criteria. To be eligible for the public housing FSS Program, a family must be a current resident of public housing. Eligible families also include current residents of public housing who are participants in local public housing self-sufficiency programs. Determinations of eligibility will be made in accordance with the relevant policies and procedures of the WHA.
Outreach efforts. An FSS Program brochure is provided to all public housing residents at the time of admission and at the annual recertification. If the resident is not interested in the program at that time, he/she will be asked to sign a participant waiver. The WHA's Self-Sufficiency Coordinator will be available on an appointment basis to discuss the program with interested residents and assist any family who has difficulty completing the FSS Program application process.
Application procedures.
Among those households eligible, the FSS Program participants will be selected from an FSS waiting list composed of those families currently residing in the WHA's public housing developments and housing choice voucher programs.
To apply for the FSS Program, a family must first indicate its interest in the program. This can be done by a referral from a WHA staff member or a self-referral to the Self-Sufficiency Coordinator. The family will then be placed on the FSS Program waiting list in the order in which it expressed interest in the program. The WHA will notify the family in writing of its placement on the waiting list and inform the family that it will be contacted when a slot is available.
When a slot becomes available, the family will be notified in writing by the Self-Sufficiency Coordinator that it has been selected for participation in the FSS Program. The family shall also be advised of the initial steps required to execute the contract of participation. The notice will include an FSS application and information registration form, FSS application, and the FSS resident needs assessment.
If the family does not respond within 14 days of the date of the notice, a second written notice shall be sent informing the family that it has been moved to the bottom of the waiting list. (The WHA staff and/or Self-Sufficiency Coordinator may contact the family in person or by phone if there is a question regarding the family's receipt or comprehension of the notification.) Documentation of such contact shall be placed in the family's file.
If the family moves to the top of the waiting list again and a slot becomes available, a second written notice will be sent giving them 14 days to respond. This mailing will include the necessary paperwork. If the family does not respond to the second notice, or responds negatively, a written notice shall be sent by the Self-Sufficiency Coordinator informing the family that its name has been removed from the waiting list. The notice will also advise the family that it may rejoin the FSS waiting list with the stipulation that it has only one other opportunity to join the FSS Program. If it does not respond to the third invitation, the family will be permanently removed from the FSS waiting list.
At the determination of the Self-Sufficiency Coordinator, the family may be asked to comply with a number of requests for action and/or information needed prior to execution of the FSS Contract of Participation. Such requests may include but are not limited to a request for: one or more meetings with the case manager, information needed by WHA staff to prepare the preliminary rent determination, or information or appointments as may be required to complete the family's individual training and service plan (ITSP). In the event that the family replies to the notice of selection but fails to comply with such a request, and WHA staff and/or case manager have made reasonable efforts to contact and assist the family with meeting these requests, the family shall be notified in writing that failure to meet these requirements within 14 days of the date of the notice will result in the family being moved to the bottom of the FSS waiting list or, if the second time being approached, removed from the FSS waiting list.
Purpose of contract. Once the application process is complete, the family and WHA sign a legally binding contract of participation. The contract sets forth the terms and conditions governing participation in the FSS Program. The contract of participation includes all individual and training services plans entered into between the WHA and all members of the family who will participate in the FSS Program.
Execution process.
Designation of head of household.
The family must designate an adult member as head of household. The head of household must meet all legal requirements in the State of Rhode Island to execute a binding legal contract of participation. The head of the FSS family is the head of the household for purposes of determining income eligibility and rent.
If the individual initially designated as head of the FSS family ceases to reside with the household in the assisted housing unit, it is the responsibility of the remaining adult members to notify the WHA within 10 calendar days. The remaining members will consult with the WHA to designate an alternative head of household. The alternative head must meet the requirements of the initial head as specified above.
Once designated, the alternative head will meet with the WHA to review the family's individual training and services plan, make any necessary modifications, and execute an FSS Contract of Participation Addendum (as applicable). The WHA will perform an interim rent determination based on the remaining household members and complete a new escrow account worksheet.
Upon approval by the WHA, the alternative head of household then becomes the designated payee of the family's escrow account. If the WHA determines that the newly designated head is unwilling to become employed, the WHA will terminate the family's FSS Program participation. In such cases, the FSS escrow account will be forfeited upon termination from the FSS Program.
Development of individual training and services plan.
The individual training and services plan (ITSP) is a written plan that is prepared for the head of the FSS family and each adult member of the FSS family who elects to participate in the FSS Program by the WHA in consultation with the family member, and which sets forth:
Each ITSP must be signed by the WHA and the participating family member and is attached to and incorporated as part of the contract of participation.
If the family is receiving welfare assistance at the time of contract execution or at some time during the term of contract, the ITSP will have a mandatory interim goal that the family shall become independent of welfare assistance for a period of one year prior to the expiration of the term of the contract or any extension thereof.
Determination of initial earned income. Upon commitment to the FSS Program, the WHA may request an interim rent determination. Upon verifying household income, the WHA will complete a new tenant certification form to establish total tenant payment and current level of earned income. This information shall be made part of the family's FSS Program file and shall be used in completion of the FSS Escrow Account Credit Worksheet.
Contract execution.
Upon completion of the above items, the family will execute the FSS Program contract of participation. The effective date of the contract shall coincide with the effective date of the TTP and base earned income specified in the interim rent determination required above and shall be the first day of the following calendar month.
At the time the contract is executed, the family will receive an explanation of the escrow account and a review of the account procedures as established by the WHA.
Successful completion of contract.
A family has successfully completed its contract of participation when one of the following has occurred:
The family has fulfilled all of its obligations under the contract on or before the expiration of the term of the contract, including any extension thereof; or
Thirty percent of the family's monthly adjusted income equals or exceeds the published existing housing fair market rent for the unit size appropriate under the WHA's occupancy standards and the family provides written certification that they are not receiving welfare assistance at that time.
Additionally, the following conditions must be met with regards to the fulfillment of a family's contractual obligations:
The head of household has been employed during the term of the contract and completed all other contract obligations. If the head is enrolled full time in an academic or job training program and is maintaining passing grades, he/she will not have to seek and maintain employment until the final year of his or her education or training is completed or until the final year of the FSS contract. If this head is not enrolled in an academic or job training program, he/she must be seeking employment in order to continue as a participant in FSS.
The head of household provides written certification that during the last 12 months no member of the family has not received assistance under any federal or state welfare programs.
This is more specifically defined as income assistance from federal or state welfare programs including TANF, SSI that is subject to an income eligibility test, medicaid, food stamps, and general assistance. Welfare assistance does not include transitional medicaid or child-care or SSI payments to guardians of disabled children. This certification does not include receiving assistance solely directed towards housing expenses (rent, mortgage, or utility payments).
Please see the Recidivism Policy regarding families who are involuntarily and voluntarily terminated, successful and unsuccessful completions, or give up their housing assistance.
Extension of contract.
Upon written request by the family and recommendation by the Self-Sufficiency Coordinator, the WHA may extend the term of the contract for a specified period of time to be determined by the WHA, provided:
Good cause for an extension of the contract term shall include, but is not limited to, the following:
Additional time is required to complete an employment probationary period and achieve an acceptable income level;
Additional time is required to complete an educational program, such as a particular degree;
Additional time is required to assist with the addition of a new family member;
A lack of appropriate job opportunity due to local economic conditions;
An unforeseen medical problem(s) within the family; or
Domestic problems (divorce, etc.)
A situation not specifically defined as good cause but which is proposed by the family will, upon recommendation by the Self-Sufficiency Coordinator, be reviewed by the WHA as grounds for extension of the contract term.
Termination of contract.
Upon recommendation by the Self-Sufficiency Coordinator, the WHA may elect to terminate the family's FSS Program participation and supportive services if it is determined that the family has failed to comply with the FSS contract obligations without good cause.
This can be done for the following reasons:
The head of the participating family refuses to seek suitable employment. Seeking employment means activities such as looking for a job, applying for work, going on job interviews, and otherwise following up on employment opportunities. Progress reports shall be required by the Self-Sufficiency Coordinator on a regular basis. Failure to maintain contact with the Self-Sufficiency Coordinator could also result in termination of the FSS contract of participation.
The determination of suitability of employment shall be made by the FSS Operational Committee in conjunction with the head of the family and shall be based on the person's skills, education, the available job market, and the ITSP. The WHA may consult with other appropriate agencies in its determination of suitability. The objective of the ITSP should be employment in an above-minimum-wage job or entry-level position with potential for advancement.
The head of the participating family refuses to maintain employment. There is no minimum time of required employment. However, the head of household must seek and maintain suitable employment sometime during the contract term. Although there may be some exceptions granted on a case-by-case basis, the ITSP shall require the head to maintain at least part-time employment, attend school, or obtain job training.
The head of household fails to complete his/her ITSP.
If the family moves from the WHA's jurisdiction and does not continue with the FSS Program or does not complete its program requirements by transferring to the FSS Program of the public housing agency having jurisdiction over the family's new place of residence.
Failure to comply with the tenant's responsibilities under the lease, including but not limited to the reporting of changes in income and household composition and maintaining lease compliance.
The determination to withhold supportive services or terminate program participation will be made on the basis of the nature and extent of the violation of the family's program obligation and the status of the family's completion of the ITSP.
Complaints and appeals.
In addition to the rights of a complaint and appeals process, as described in the WHA's grievance procedure and in compliance with 24 CFR 882.216/887.504, the FSS Program participant will have access to the same process on those decisions denying an applicant:
Listing on the FSS waiting list;
Issuance of an FSS contract from placement on the FSS waiting list on the basis of a lack of adequate supportive services being currently available;
Continued participation in the program as the result of termination of the family's contract of participation;
A request for an extension of the contract on the basis of a good cause;
Distribution of the family's escrow account at the end of the contract term or at the completion of the family's obligations under the FSS contract; or
Entrance into FSS due to nonlease compliance.
Other determinations made by the WHA, the operational committee, or the coordinating committee under the terms of this chapter shall not be subjected to the above complaint and appeals process.
