Housing authority approves FY2025 annual plan and policy updates, including HOTMA changes and PBV referral clarifications

The Housing Authority voted unanimously to authorize the chief executive officer to submit the housing authority's five-year plan update, annual plan and capital grant funding to the U.S. Department of Housing and Urban Development for fiscal year 2025, as mandated by Section 511 of the Quality Housing and Work Responsibility Act of 1998.

Sawadee Lange, authority counsel, presented the changes since the annual plan posted for public comment in May: updated financial resources (including the Emergency Housing Voucher line), revised homelessness point-in-time data to reflect new preliminary 2024 figures, and an audit update that will include the 2023 audit attachment when the plan is filed with HUD. Lange said staff also added the authority's stated Faircloth-to-RAD commitment and site-specific language for Plaza East to the new activities section.

Policy changes discussed in detail include:

- PBV referral chart clarifications: the exhibit that lists PBV units and referral entities was revised to make clear referrals are unit-level and tied to unit-level prequalifiers (for example HOPWA or other overlays); the revised language prevents the misinterpretation that a sponsor would be required to accept a large influx of referred residents beyond the services they can provide.

- Discrimination-complaint procedures: staff added a provision that an authority investigation will commence after a 30-day window and committed to developing forms and processes; staff said filing a HUD complaint remains an option at any time and tenants do not have to wait for the authority's process to proceed with HUD.

- INSPIRE/HQS implementation: changes proposed earlier to HCV policies related to the INSPIRE inspection system were reversed and INSPIRE implementation for HCV has been extended a year; public housing ACOP changes related to INSPIRE remain in force for sites that already received INSPIRE reviews.

- Income and reexamination adjustments under HOTMA: staff explained that new federal rules (HOTMA) change some verification thresholds; policy language will be generalized in the annual plan while procedural materials and intake packets will be revised before the changes take effect (the authority said changes will not be implemented until after October 1, 2024, and families would see them at their next reexamination or interim).

Public commenters and tenant advocates urged clearer notice and procedural protections for discrimination complaints, reconsideration of confidentiality language for domestic-violence documentation so victims and their legal representatives can access necessary records, and more accessible communication about wait-list openings and policy changes. Staff acknowledged those concerns and said revised forms and communications will be produced during the implementation window.

Vote and outcome: Commissioner Lewana Kim moved to approve the plan; Commissioner Lindau seconded. Roll call votes recorded Aye from Commissioners Pikes, Kim, Lindau and President Torres; the motion passed.

Why it matters: The annual plan and attachments constitute the authority's public filing with HUD and set out program priorities, funding assumptions and policy changes that will affect tenant eligibility, inspections and grievance processes across authority programs.

Next step: Staff will submit the plan to HUD with the updated audit and attachments and prepare the procedural materials and outreach promised to residents ahead of the October implementation timeline for certain policy changes.