2013 CMHA HCVP Admin Plan - Cuyahoga Metropolitan Housing ...

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C. STEPS THE PHA WILL TAKE TO PREVENT PROGRAM ABUSE AND FRAUD The PHA management and staff will utilize various methods and practices (listed below) to prevent program abuse, non-compliance, and willful violations of program rules by applicants, families and owners. This policy objective is to establish confidence and trust in the management by emphasizing education as the primary means to obtain compliance by families and owners. Review and explanation of Forms - Staff will explain all required forms and review the contents of all documents prior to signature. Landlord/Tenant Fraud Letters - are returned along with the RFTA packet and indicate acknowledgment of the landlords’ and tenants’ responsibilities to adhere to program requirements. D. STEPS THE PHA WILL TAKE TO DETECT PROGRAM ABUSE AND FRAUD The PHA Staff will maintain a high level of awareness to indicators of possible abuse and fraud by assisted families and owners. Quality Control File Reviews. Prior to initial certification, and at the completion of all subsequent recertifications, a random selection of files will be reviewed per year per HUD guidelines. Such reviews shall include, but are not limited to: Assurance that verification of all income and deductions is present. Authenticity of file documents. All forms are correctly dated and signed. Observation. The PHA management and staff (to include inspection personnel) will maintain high awareness of circumstances which may indicate program abuse or fraud, such as unauthorized persons residing in the household and unreported income. Public Record Bulletins may be reviewed by Management and Staff. State Wage Data Record Keepers. Inquiries to State Wage and Employment record keeping agencies as authorized under Public Law 100-628, the Stewart B. McKinley Homeless Assistance Amendments Act of 1988, may be made annually in order to detect unreported wages or unemployment compensation benefits. Credit Bureau Inquiries. Credit Bureau inquiries may be made (with proper authorization by the participant) in the following circumstances: At the time of final eligibility determination When an allegation is received by the PHA wherein unreported income sources are disclosed. When a participant's expenditures exceed his/her reported income, and no plausible explanation is given. Copyright 2000 by Nan McKay & Associates To be printed only with permission of Nan McKay & Associates Unlimited copies may be made for internal use Approved by CMHA Board of Commissioners October 3, 2012 183 | P a g e
E. THE PHA'S HANDLING OF ALLEGATIONS OF POSSIBLE ABUSE AND FRAUD The PHA staff will encourage all participating families and owners to report suspected abuse to the PHA. All such referrals, as well as referrals from community members and other agencies, will be thoroughly documented and placed in the case file. All allegations, complaints and tips will be carefully evaluated in order to determine if they warrant follow-up. The PHA will not follow up on allegations which are vague or otherwise non-specific. The PHA will only review allegations which contain one or more independently verifiable facts. File Review: An internal file review will be conducted to determine if the subject of the allegation is a family or owner of the PHA, or other interested party, and, if so, to determine whether or not the information reported has been previously disclosed by the family, owner or other interested party. It will then be determined if the PHA is the most appropriate authority to do a follow-up (more so than police or social services). Any file documentation of past behavior as well as corroborating complaints will be evaluated. Conclusion of Preliminary Review If, at the conclusion of the preliminary file review, there is/are fact(s) contained in the allegation which conflict with file data, and the fact(s) are independently verifiable, the PHA will initiate an investigation to determine if the allegation is true or false. F. OVERPAYMENTS TO OWNERS If the owner has been overpaid as a result of fraud, misrepresentation or violation of the Contract, the PHA may terminate the Contract and arrange for restitution to the PHA and/or family as appropriate. The PHA will make every effort to recover any overpayments made as a result of owner fraud or abuse. Payments otherwise due to the owner may be debited in order to repay the PHA or family, as applicable. G. HOW THE PHA WILL INVESTIGATE ALLEGATIONS OF ABUSE AND FRAUD If the PHA determines that an allegation or referral warrants follow-up, a person designated by the HCVP Director to monitor the program compliance will conduct the investigation. The steps taken will depend upon the nature of the allegation and may include, but are not limited to, the items listed below. In all cases, the PHA will secure the written authorization (where necessary) from the family, owner or other interested party for the release of information. Credit Bureau Inquiries (CBI). In cases involving previously unreported income sources, a Copyright 2000 by Nan McKay & Associates To be printed only with permission of Nan McKay & Associates Unlimited copies may be made for internal use Approved by CMHA Board of Commissioners October 3, 2012 184 | P a g e
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CUYAHOGA METROPOLITAN HOUSING AUTHO
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J. INELIGIBLE FAMILIES.............
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E. ASSISTANCE TO FAMILIES WHO CLAIM
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I. MISREPRESENTATION IN COLLUSION W
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Copyright 2000 by Nan McKay & Assoc
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24 CFR Part 5: General Program Requ
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1. Objective I: Outreach to Low-Inc
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Once the person's status as a quali
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4. Utility Allowance Schedule 5. HQ
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and by other suitable means. Notice
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placement in foster care shall not
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Which of the two new family units h
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considered individually before the
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If the family has engaged in or thr
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evidence that the members of the ho
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3) The public notice must state any
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information is complete. The interv
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The following are examples of types
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The residency preference is require
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A point system will be used to prio
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Owners of Mod Rehab properties can
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Space may be provided for a child w
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HQS GUIDELINES FOR UNIT SIZE SELECT
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4) Child Care Expenses: Deducted fo
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income. Therefore, for disabled fam
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A student (other than the head of h
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If the absence which resulted in te
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K. REMOVAL OF SPOUSE FROM FAMILY UN
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Nonprescription medicines will be c
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Verification Before Denying a Reque
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Written Third Party Verification (T
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The PHA will obtain written verific
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3) Documents such as manifests, app
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Acceptable verification may include
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Attendant Care: 1) Attendant's writ
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Verification of Citizenship/Eligibl
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J. CERTIFICATION OF DOMESTIC VIOLEN
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2. Mover Briefings Briefings are co
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20) Agent form. 21) W-9 form for la
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new families cannot agree as to whi
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In addition to the above, at the ti
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domestic violence, dating violence,
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name and address of the landlord at
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after the family and owner submit a
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. Must have a toilet and a fixed wa
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Exceptions may be made for multi-fa
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K. DETERMINATION OF RESPONSIBILITY
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The PHA will not approve a lease un
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Housing Assistance Payments, termin
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easonable accommodation for a perso
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If the review indicates there is an
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G. NOTIFICATION OF RESULTS OF RECER
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D. PROCEDURE FOR MOVES [24 CFR 982.
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If the family leases up successfull
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During the term of the lease the ow
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actual or threatened domestic viole
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Requirement to Deny Admission or Te
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control, shall not be cause for ter
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The PHA prohibits admission if any
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PHA must provide the subject of the
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accomplished. D. FAMILY OBLIGATIONS
Page 133 and 134: Lease Violations The following crit
Page 135 and 136: G. ZERO ($0) ASSISTANCE TENANCIES T
Page 137 and 138: Copyright 2000 by Nan McKay & Assoc
Page 139 and 140: HCVP assistance or leased under any
Page 143 and 144: the HAP contract. Separate agreemen
Page 147 and 148: If the family requests a move to an
Page 149 and 150: The family is given the opportunity
Page 151 and 152: Determination that a unit is not in
Page 153 and 154: When the PHA receives a request for
Page 155 and 156: Within 15 days, the PHA shall send
Page 159 and 160: C. CONGREGATE/SHARED HOUSING Descri
Page 161 and 162: “Qualifying families” means eld
Page 163 and 164: ecomes aware the unit is vacant) S
Page 165 and 166: Administrative Plan. Families must
Page 167 and 168: o The unit meets HUD Housing Qualit
Page 169 and 170: The family must comply with the fol
Page 171 and 172: the PHA determines that it does not
Page 173 and 174: 3) CMHA will retain all records lon
Page 175 and 176: ecords, the intended date of the di
Page 177 and 178: 08-25 Rent Increase Determination 0
Page 179 and 180: 08-60 Damage Claim 08-61 Quarterly
Page 181 and 182: 08-103 Applicant Files- Denied Reta
Page 183: XXII. PROGRAM INTEGRITY A. INTRODUC
Page 187 and 188: J. EVALUATION OF THE FINDINGS If it
Page 189 and 190: A secondary purpose of the Case Con
Page 191 and 192: XXIII. GLOSSARY A. ACRONYMS USED IN
Page 193 and 194: TR TTP UA UIV URP Tenant Rent Total
Page 195 and 196: COMMON SPACE. In shared housing: Sp
Page 197 and 198: ELDERLY HOUSEHOLD. A family whose h
Page 199 and 200: FMR/EXCEPTION RENT. The fair market
Page 201 and 202: IMPUTED WELFARE INCOME. An amount o
Page 203 and 204: MINOR. A member of the family house
Page 205 and 206: PUBLIC HOUSING AGENCY (PHA). PHA in
Page 207 and 208: another person; and in the course o
Page 209 and 210: soon as s/he learns of the vacancy,
Page 211: SECTION 214. Section 214 restricts
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