VAWA 2017

VAWA requirements have been updated, and the deadline for implementation of the new requirements is May 15.  

To review, VAWA stands for the Violence Against Women Act, and it protects victims of domestic violence from losing their housing due to their status as victims.  While the original Act protected only residents of Section 8 housing, the Reauthorization Act of 2013 expanded those protections to cover the following housing programs:

• HUD HOME Investment Partnership Programs
• HUD 202 
• HUD 202/8
• HUD 202 PRAC
• HUD 236
• HUD 811 
• HUD 222(d)(3) BMIR
• HOPWA Housing Program
• HUD's McKinney-Vento homeless programs
• Low Income Housing Tax Credit Program (LIHTC)
• USDA 515 housing (click the link for USDA guidance)

HUD Sites:  
HUD VAWA forms noted below are all linked on the blog in procedure 3-38:  VAWA

VAWA Final Rule 
Published 11/16/2016

Notice of Occupancy Rights under VAWA:  
This should be provided with a copy of the Certification form and resource list as follows:

• with applications; 
• to existing household members at their next certification; 
• to rejected applicants; 
• at move-in; 
• with any notice of termination; 
• with any notice of eviction (YOU WILL NEED TO ADVISE YOUR ATTORNEY)

Certification of Domestic Violence, Dating Violence, Sexual Assault or Stalking
This should be provided with a copy of the above notice as noted above, and also upon request by an individual needing to file for protected status under VAWA.

VAWA RSP Clarification
Must be filed with your RSP (be sure to note RSP date of approval on the form, and have your Board approve the addition of this language to the RSP).  RSPs revised from this date onward will have this language included in the Unit Transfer section.

VAWA Emergency Transfer Plan and Support Services List
Must be completed by all applicable sites and emailed to Linda no later than April 1, 2017.  It should also be posted at your site, and kept with your Resident Selection Plan.  Please note that transfers due to VAWA status take priority over all other types of transfers, including reasonable accommodations.  This is because VAWA status indicates an imminent risk.  Those transferring due to VAWA status may only be transferred to units they qualify for (i.e., generally cannot be transferred to an adapted unit if they do not need the features).

USDA Sites:
USDA VAWA forms noted below are all posted on the blog under the procedure 3-38:  VAWA

USDA VAWA Guidance handout.
This notice details USDA guidance on VAWA.

Notice of Occupancy Rights under VAWA:  
This should be provided with a copy of the Certification form and resource list as follows:

• to existing household members at the next certification, 
• to rejected applicants 
• at move-in
• with any notice of termination, 
• with any notice of eviction.

Certification of Domestic Violence, Dating Violence, Sexual Assault or Stalking
This should be provided with a copy of the above notice as noted above, and also upon request by an individual needing to file for protected status under VAWA.

VAWA RSP Clarification
Must be filed with your RSP (be sure to note RSP date of approval on the form, and have your Board approve the addition of this language to the RSP).  RSPs revised from this date onward will have this language included in the Unit Transfer section.

VAWA Emergency Transfer Plan and Support Services List
Must be completed by all applicable sites and emailed to Linda no later than May 1, 2017.  It should also be posted at your site, and kept with your Resident Selection Plan.  Please note that transfers due to VAWA status take priority over all other types of transfers, including reasonable accommodations.  This is because VAWA status indicates an imminent risk.  Those transferring due to VAWA status may only be transferred to units they qualify for (i.e., generally cannot be transferred to an adapted unit if they do not need the features).

All of the VAWA forms have been updated on the Forms and Procedures page (it's procedure 3-38, all the way at the bottom of the page).

If you have any questions on VAWA, please contact me, and watch for notification of a training conference call to be scheduled soon.

Meet January's Rock Star of the Month!

Please join me in congratulating January’s ROCK STAR of the month:   Michael Collins. 

Michael received a You Rock Award for going the extra mile every day.  He is the Live-In Superintendent at Hearth Homes and was without power in his apartment for 4 days.  We offered to put him up in a hotel but he refused.  He wanted to stay on site so he could tend to the residents and perform his job duties.  He was chosen at random from the December You Rock award winners.   Mike has been awarded with a paid day off.

Let’s get to know Mike better:

1.     How long have you worked at EHM and your current location?

        3 years

2.     What is your current position?

        Superintendent

3.     Have you held any other jobs at EHM?

        No

4.     What do you like most about working here?

        Learning new things

5.     What is your favorite EHM memory?

        Tenant Appreciation Luncheon

6.     Do you have any advice for new employees?

        Take notes while learning new things. Be aware of your surroundings 

        and of things that need to be done.

7.     What do you like to do outside of EHM?

        Spend time with family and friends.

«««CONGRATULATIONS MIKE ««« 

  

Luz Pabon is the EHM Rock Star of the Month!  Luz was nominated for "You Rock" in October in recognition of the exceptional efforts she put forth to prepare Broad River Homes for their Management Occupancy Review!  

Luz joined EHM in November of 2010 and works at Broad River Homes and Miss Laura Raymond Homes.

We wanted everyone to get to know our Rock Star a little better so we had the chance to ask her some questions about her life and work with EHM.

  What is your current position?

- I am an Occupancy Specialist/ Assistant Administrator at Broad River Homes, and Occupancy Specialist At Miss Laura Raymond Homes

 Have you held any other jobs at EHM?

- I have covered both Broad River Homes  and Miss Laura Raymond Homes at the same time during  periods when they did not have Administrators. I do all Annual Recertifications for both Sites (96).

 What do you like most about working here?

-I love the peaceful environment at Broad River Homes ,we are lucky to have a great group of Residents, wonderful staff ,everybody knows our responsibilities and also we all help each other which  is good for us, for  the  Residents and for the company.

 What is your favorite EHM memory?

 -When Robert Shulman gave the opportunity to work for Broad River Homes, he believed in me.

 Do you have any advise for prospective staff?

 - Just do your best every day, help as much as you can and live in harmony with everybody.

What do you like to do outside of EHM?

I would love to travel with my family to other Countries.

Resident Selection Plans

Recently, I've been receiving questions regarding resident selection that indicate that not everyone has taken the time to read one of the site's most critical documents - the Resident Selection Plan.

After reading this post, please block out some time to read your selection plan through entirely.  Keep a copy posted nearby as a reference.  Why?  Because knowing your selection plan gives you the ability to have answers handy, and to be able to point at a reference that explains who qualifies to live in your property, who doesn't, and how we screen applicants.  It also answers some key questions about what to expect as a tenant.  

So What's in a Selection Plan?
Selection plans detail regulatory requirements such as income limits, age restrictions, required screening elements (such as provision of SSNs or DOB),  required reasons for rejection, wait list requirements, and fair housing information.   They also detail elements that are more individual to a site or management company, such as any additional screening requirements (such as references), where and how to apply, the interview process, pet policies, smoking policies, etc.  And finally, there are some legal requirements, such as Fair Housing, VAWA (for certain sites), and other items.

Using a Selection Plan:
Your Resident Selection Plan must be posted on site where applicants and residents can refer to it if they choose.  When reviewing applications, you must do so in compliance with the Resident Selection Plan.  While some elements are fairly easy to keep in mind (income limits and age restrictions, for instance), others are not.  Some of the rules that don't always stay in your memory are:

Affordability - If the unit is not subsidized, applicants must be able to demonstrate an ability to afford the rent and other fees.  Generally speaking , this means that they must be able to pay the rent and other mandatory fees using no more than 40% of their gross income.  If they have assets that can be drawn down, or if they can demonstrate that they were paying a higher rent elsewhere, they may be able to move in using a higher percentage of this income.  The calculation of affordability, though, must occur when you have applicants for unsubsidized units.

Refusing a Unit - If an applicant refuses a unit, what happens?  Whether they go to the bottom of the list, or are removed from the list, is determined by the policy laid out in your Selection Plan.

Charges in Addition to Rent - This section details anything that residents are required to pay for other than their rent, such as key fees, air conditioning, congregate fees, lockout fees, etc. 

Definitions - The regulatory definitions of elderly, disabled, and family are all provided in the Selection Plan, so that applicants can understand what we mean when we use them.

Adult Children - For some properties (HUD 202/8 and HUD 202 PRAC properties), adult children can only be added to the lease after the initial move-in if they are necessary for care.  This is noted in the Resident Selection Plan.  Should the qualifying member of the household move-out or pass away, whether or not that adult child can stay afterwards is also described in the Plan.

Updates:
Resident Selection Plans must be updated as needed.  All sites have now been placed on an update schedule which will time the update of the Selection Plan and Resident Handbook with the update of the Affirmative Fair Housing Marketing Plan.  It is important to remember that changes to the Selection Plan must be communicated to interested parties.  For instance, when a property decides to become smoke-free, that change must be communicated to applicants.

Summary:
To use a driving analogy, Resident Selection Plans contain both the road map and the driver's manual for the selection process.  Knowing what's in them, and referring to them when needed, can ensure that you are staying on the right road, and that you're not going to get pulled over for breaking the rules.

Now get reading ;)

Be on the Lookout - Electrical Rate Scam!

Recently, one of our sites became aware that individuals were going door-to-door, claiming to be looking to assist residents with a reduction of their electrical rates.  These individuals were asking for copies of resident bills (which as you know include account numbers).  

Eversource, the company whose customers were most recently targeted, wants people to be aware that:

• Eversource representatives never ask for instant payment in person or over the phone.
• Eversource representatives do not require the use of prepaid debit cards (such as Green Dot MoneyPak, Vanilla or Reloadit).
• Eversource representatives never request customers meet at a payment center, such as a department or grocery store, to make a payment.
• Eversource does not solicit door-to-door or on the phone on behalf of third-party energy suppliers.
• Eversource representatives always carry company-issued photo identification and will always provide it when asked.
• Contractors working for Eversource ​always carry documentation explaining the nature and location of their work.
• Customers who are scheduled for disconnection due to nonpayment receive written notice via the U.S. mail which includes the actions they can take to maintain service.
• Eversource almost never makes unsolicited house visits. Exceptions might include accessing, maintaining, or ensuring the reliable and safe operation of our equipment.
• If you’re not sure the person is an Eversource employee, call us. We’ll be glad to verify if work is scheduled at or near your home or business and the identity of the employee.

United Illuminating has also warned of scams in the past.  

In general, individuals soliciting your residents door-to-door should be asked to leave immediately.  You should have signage posted on your property advising that solicitors are prohibited.  Be aware that certain entities, such as volunteer fire departments on a donation drive, or religious entities, require a more delicate approach, and you should speak with your Regional Manager, the Assistant Director of Property Management, or the Director of Property Management for guidance in these unique situations.

More information on recent electricity scams here, here, and here.

A template notice you can use to advise residents is here.

Odds and Ends

All sites – Reasonable Accommodations:

Recently, there has been a sharp increase in the amount of requests for assigned parking, assigned accessible parking, and bathroom modifications (including barrier-free showers).  In many cases, there is a significant delay in making a decision on the request due to the need to clarify the needs with the verifier.  In addition, there has been some confusion on who may be considered a qualified verifier.

Although it is true that a verifier does not necessarily have to be a physician or health care provider, this should always be our preferred source for verification.  In any case, the verifier must be someone who we believe is reasonably capable of assessing the individual’s disability status and need.  For instance, while my friend may be able to tell you I have a disability, they may not be able to tell you exactly how far I am able to walk (which becomes relevant for assigning a parking space) or how high I can safely lift my leg (which may be relevant for a tub cut).  It is reasonable for us to make inquiries related to the need of the individual requesting an accommodation.

For this reason, I have developed two new forms, which should be used effective immediately. 
They are as follows:

Request for Bathroom Modification RA Packet

Request for Assigned Parking RA Packet

You will find that both include some specific questions designed to assess exactly what is needed.  This should help us in determining what the need is, and addressing needs in the most economic and reasonable way possible.

Please note that while Resident Service Coordinators, in general, can verify the need for accommodations / modifications, it is likely that the RSC will generally not have the requisite knowledge of the specifics necessary to verify these items. 

If you have a situation where there is no physician who can verify, or a unique situation that appears to need detailed discussion, please don’t hesitate to contact me.

Remember, for those of you who do not have federal funding, although you may not have to pay for accommodations / modifications, you often still are required to permit them.  Please make sure that you are forwarding any requests.

Another important note – please take care when a resident requests something that ordinarily would not be allowed.  Make sure you are not dealing with a Reasonable Accommodation request before you say no.  If you are unsure, please check with your RM, me, or Tammy before you say no.

All Sites – Site Inquiries:

In my travels recently, I’ve overheard a number of telephone conversations (or, rather, half of them) regarding inquiries about housing.  Please be very, very careful when answering questions about your facility.  Remember to use your site script.  When potential applicants begin asking about eligibility, the best answer is always “I have an application packet that I can send to you which will answer many of your questions.  If you still have questions after you review it, please feel free to give me a call.”  Where you can potentially get yourself in significant Fair Housing trouble is if you are perceived as discouraging someone from applying.  If you absolutely must answer questions (and again, you want to generally refrain from discussing eligibility until you have an application in front of you), be sure to refer to your site script and your facility description, so that you can be sure to give the exact same answer every time, in a manner that is consistent with program guidelines and your printed materials. 

If your wait list is closed, you may advise that the wait list is closed when responding to inquiries.  Please also advise the caller as to how you will provide notice when the wait list opens.

HUD Sites – Deceased Tenants:

Recently, I met with a family member of a deceased tenant.  She was concerned because she reportedly had been told that they had to vacate the unit in two weeks, even though her mother had paid the full month’s rent for June.  As this is a common area of confusion, I wish to make it clear what happens to subsidy when the sole member of a household dies.  Please be sure that you are using Form 3-10c, the Notice Regarding Move-Out, and that you are reviewing this with residents when they move in.  You might also want to keep a copy handy to refer to when speaking with family. 

It is NOT true that a unit must be vacated within 14 days of the sole household member’s death.  It IS true that subsidy cuts off at that point.  If items remain in the unit after that point, the estate is charged the pro-rated unsubsidized rent for the unit.  If the tenant already paid their rent, you would simply charge the difference between what the tenant paid, and what is owed.  If you are at all unsure as to what you need to charge in these cases, please speak with your RM or with me.  We would be happy to help you with the calculation. 

All sites – AFHMP:

HUD - Recently, I received information that conflicted with previously given HUD guidance regarding Marketing plans.  It has been recently clarified by the HUD FHEO office in Boston that if your wait list is CLOSED, you do not have to market.   However, if your wait list is open, you must do your AFHMP marketing every year.  Please be sure to keep copies of all advertising and all letters in your AFHMP file.  This is requested at the MOR.

USDA – When I submit your AFHMP, USDA/RD requests copies of all advertising, so be sure that you have those copies available when I request information for your AFHMP updates.

DOH – Recently, DOH has started to request copies of actual advertising as well, so be sure to keep copies of all ads and letters.

HUD Issues Notice Regarding "Previous Housing Code"

On March 22nd, Navigate Affordable Housing Partners advised of an important notice from HUD.

This notice, which you can download here, advised of the following:

HUD is now revising how they track homeless individuals and families in assisted housing.  As a result, they have revised the codes in TRACS that relate to homelessness.  The changes are detailed below.

New codes have been added to the MAT 10, Section 2,"Previous Housing Code," and others have been removed.

The updated codes are as follows: 

1.  Substandard (means physically substandard - does NOT include overcrowding)
2.  Without or Soon to be Without Housing (no longer valid for new move-ins)
3.  Standard
4.  Conventional Public Housing (owned by a Public Housing Authority)
5.  Lacking a Fixed Nighttime Residence (NEW)
6.  Fleeing / Attempting to Flee Violence (NEW)

Previous Housing Code 2 - Without or Soon to be Without Housing now only applies to records transmitted under TRACS 202.C, or corrections to those certifications.  

Move-Ins that occurred after October 1, 2015 may need to be corrected.
If you had a move-in that occurred after that date, and you coded them as Previous Housing Code 2 - Without or Soon to be Without Housing, you will need to correct the certification and send it through TRACS as soon as possible. The move-in will need to use code 1, 3, 4, 5 or 6.

Future Changes:
TRACS will soon generate a fatal error for Previous Housing Code 2.

If you have questions about this notice, or need assistance making corrections, please speak with your Regional Manager, or contact Pam.

They're Heeeeeeeere......

OK, maybe not THAT scary.

HUD has issued the FY 2016 income limits, effective 3/28/2016.  USDA sites, this means that the income limits should soon be posted to MINC - be on the lookout.  

How do the numbers stack up against last year's limits?  Kind of a mixed bag there.  Due to the way calculations are done, some slots have gone up slightly; some have decreased slightly.  There have not been huge changes either way, but it may very well change things for those folks who are close to the limit.  Be aware that some people on your wait list may no longer qualify.  

The income limits are here: 
https://www.huduser.gov/portal/datasets/il/il16/index_il2016.html

For those of you using OneSite, you will need to update the income limits in your system.  

To do so:

1.            Go to:  https://www.huduser.gov/portal/datasets/il.html

2.            Navigate to your income limits; print them out and make sure they are posted on site.

3.            Open OneSite.

4.            At the top right corner of the screen, click “Setup.”

5.            At the left side of the screen, in the blue menu bar, click “Affordable” under the

               “General property” category.

6.            In the center area of the screen, click “Income Limits” (third item down).

7.            In the window that opens, click “Edit” next to your HUD income limits.

8.            Your income limits will come up.  Be sure to enter the correct start date – 3/28/2016.

9.            Check the following settings to make sure they are correct:

               *     At the top of the window, make sure that “Round income limits to the 
          nearest $50 is UNCHECKED.

                

               *     Below that, make sure that you have CHECKED the box that allows you to 

                      make the table fully editable.  This is important, as the automatic calculations 

                      often do not match what HUD has; you will need to enter the numbers manually.

10.          Enter the income limits that you need.  For most sites, you will be filling out the 

               30% income limits, 50% income limits, and the 80% income limits completely.  

               You should also add the 4-person 100% limit.  For all items you do not need, 

               you should enter zero (OneSite will not allow you to leave these blank

11.          Click “Save” in the bottom right corner of the window to save your changes, and 

               you’re all set.

EHM Staff in the Community - Debbie Pelletier

Deb hard at work on budgets

Debbie Pelletier is the Asset Manager at EHM.  In addition to steering us through the complicated world of budgets, replacement reserve requests, EIV, REAC, and other regulatory and financial matters, Deb also keeps busy in her off hours.  Besides her passion for sailing and all things nautical, Deb has been involved in the annual Parkinson's Unity Walk for the last five years.  

The Unity Walk raises funds for research into a cure for Parkinson's Disease.  Parkinson's is a devastating illness that affects nearly one million Americans.  A chronic and progressive movement disorder, Parkinson's currently has no cure. Research is critical to finding effective treatments, and hopefully a cure.

100% of donations raised through the Unity Walk go to support the following organizations:  

• the American Parkinson Disease Association
•  the National Parkinson Foundation; 
•  the Parkinson's Action Network; 
•  the Parkinson's Disease Foundation; 
• The Michael J. Fox Foundation for Parkinson's Research; 
• The Parkinson Alliance
• The Parkinson's Institute and Clinical Center

Deb and her team, Deen's Day Trippers, will set off through NYC's Central Park on April 23rd of this year.  We wish them all the best of luck, with warm and benevolent weather!

If you would like to learn more about the Unity Walk, join Deb's team, or start your own, you can visit Deb's page here.


Care to share what you're up to in the community?  Email Pam

Welcome Back Artie!

To many of us at EHM, our coworkers become a second "family."  This is very true at Juniper Hill Village, where a variety of staff - Administrative, Maintenance, Resident Services, ALSA, and Dietary - come together to keep this very unique property running smoothly and enriching the lives of its residents.

Recently, a member of the JHV family experienced a serious medical issue, and has been away for several weeks.  For those of you who do not know JHV's Chef Manager Artie, he is the type of person who is always ready with a bright smile and a cheerful attitude.  He and the JHV dietary staff work hard to create nutritious, tasty, and creative meals for the Juniper Hill Village residents.  When the supervisory staff come to visit, we are always happy to sample some of their work!  It is quite the challenge to create variety, appeal to different tastes, and keep everything on target with the budget, but Artie and his staff are up to the challenge.

In what was truly a wonderful gift this holiday season, four weeks to the day after medical needs forced his absence, Artie returned for a visit.  He is pictured here with Kimmie and Jessica.  JHV's Administrator, Marlene, told me that Artie is well-known for giving Kimmie "rabbit ears"  in photos, and so Kimmie is returning the favor here.

Artie, we are so very happy that you stopped by to say hello, and wish you a speedy and full recovery.  We also wish you nothing but health and happiness in the coming New Year.

Decking the Halls at EHM

Bonney Brook, 2nd floor

Bonney Brook, 3rd floor

Bonney Brook, 1st floor

 Hearth Homes

The Ripton 

Marian Heights Community Room

Marian Heights 1st floor

On this Veterans' Day, we are proud to count so many Heroes among our staff and residents.  We thank you from the bottom of our hearts for your selfless service to our country. 

This nation will remain the land of the free only so long as it is the home of the brave. -Elmer Davis

"Veteran rides in Memorial Day Parade May 2009, Gloversville, NY" - by las - initially, Flickr

These heroes are dead.  They died for liberty - they died for us.  They are at rest.  They sleep in the land they made free, under the flag they rendered stainless, under the solemn pines, the sad hemlocks, the tearful willows, and the embracing vines.  They sleep beneath the shadows of the clouds, careless alike of sunshine or of storm, each in the windowless Place of Rest.  Earth may run red with other wars - they are at peace.  In the midst of battle, in the roar of conflict, they found the serenity of death. I have one sentiment for soldiers living and dead:  cheers for the living; tears for the dead.

- Robert G. Ingersol

EHM is on Facebook!

That's right - we're on Facebook.

Look for us as Elderly Housing Management (you can also click the button above).

Please "like" our page.  And while you're there, why not check out some of our recent posts:

Fun events at Davenport-Dunbar: 
Caribbean Cruise
Cultural Expo

We've also posted some great pictures of our sites.

And coming tomorrow - a birthday wish for one of our residents.

Please stop by and say hello - and be sure to check in frequently for news and updates!