Moving To Moving Work Application

PART I: Moving to Work Plan and Landlord Incentive Activities

A. MTW Plan

1. Vision for Norwalk Housing Authority's Moving to Work Program

The Moving To Work (MTW) program was established in 1996.  HUD is expanding MTW by adding an additional 100 MTW Public Housing Agencies (PHAs) over seven years.  HUD has invited PHAs to apply for the MTW Cohort #4 - Landlord Initiatives demonstration. The NHA is submitting a formal application to participate in the MTW Expansion under Cohort #4.

i.  NHA's Unique Vision - The Norwalk Housing Authority is an innovative, progressive, high performing housing authority whose mission is to build, maintain, and preserve safe, affordable housing through well managed, mixed income properties that strengthen our community. The flexibilities allowed through the Moving-to-Work Program will support NHA's vision of empowering residents to achieve self-sufficiency by increasing family housing opportunities, supporting deconcentrating assisted families, encouraging greater landlord participation , promoting landlord retention, and reducing administrative burdens.

The vision of the NHA is aligned with the overall goals of the MTW program:  

Cost Savings

The NHA hopes to reduce administrative costs through the ability to established higher payment standards. Higher payment standards will reduce the number of tenancy requests that are denied due to units being determined as not affordable under regulations. In addition, fewer families will move due their out-of-pocket rent costs increasing in response to increased rents. NHA will experience savings by the reduced need for reissuing vouchers and leasing paperwork to families. Not only will this reduce administrative costs, but will better allow the NHA to house families in higher opportunity areas.

Self-Sufficiency for Residents

The NHA has a robust Family Self-Sufficiency Program and Homeownership Program, and has experienced great success in implementing its EnVision Center demonstration program, supporting the following four pillars: (1) Economic Empowerment, (2) Educational Advancement, (3) Health and Wellness, and (4) Character and Leadership. The increased ability for families to lease up in areas of low poverty concentration improves opportunities for education, job training, employment, medical treatment, and child care. These well support the four pillars that directly promote family self-sufficiency. Increased payment standards will decrease family shares, which will increase income families have available for needs other than housing costs.  

Housing Choice

The ability for NHA to raise its payment standards will support NHA's existing efforts to encourage families with and without children to move to opportunity areas throughout the Norwalk community.  All landlord initiatives were selected with the intent to promote owner participation across the entire Norwalk community, which will increase housing choices. All MTW cohort 4 actions selected focus on helping families successfully move into homeownership and achieve housing stability in low poverty areas.

Why MTW?

The City of Norwalk is a microcosm of Fairfield County, comprised of dramatic disparities between lower opportunity and higher opportunity neighborhoods.  NHA has a long history of policy initiatives designed to help our Section 8 families move into these higher opportunity communities.  Although we have demonstrated some success, we have always believed that administrative limitations, including FMR/payment standard ceilings and the ability to entice landlords into the Section 8 program in the higher opportunity communities, has greatly reduced our ability to expand this program.  While currently our Section 8 families are able to lease up, they are not always able to lease up in higher opportunity neighborhoods.  The administrative flexibilities provided with the MTW Cohort 4 are precisely the tactics we can utilize to implement our theories. The MTW Cohort 4 initiatives as shown in Section 4 have the potential to greatly expand the number of Norwalk Section 8 families that can successfully move into higher opportunity areas.

ii.  Skills and Experience of NHA Personnel

The Norwalk Housing Authority has a highly experienced and skilled workforce under the leadership of the Executive Director, Mr. Adam Bovilsky.  However, realizing some initiatives require expert skill sets not readily available within the agency, NHA maintains a diverse, capable pool of private-sector experts and partners to fill any skill gaps needed to ensure the success of the NHA programs and initiatives. In addition, NHA has capable and well-trained staff to handle Section 8 and public housing screenings, inspections and recertification's.  Staff are regularly trained on regulatory and fair housing issues necessary to their work and have many years of experience with the programs. 

Mr. Adam Bovilsky, Executive Director - Adam is a visionary, advocate and innovator. He has spent the past 15 years developing solutions to improve families' quality of life in underserved communities. When not leading the Norwalk Housing Authority, he serves as a board member of Norwalk Acts and Opening Doors of Fairfield County.  

Ms. Krasimira Carlucci, Deputy Director - With over 11 years of housing experience, Krasimira oversees all PHA housing operations, including the HCV and public housing programs. Having previously served as the Director of Operations, she has a wealth of experience in finding creative and innovative approaches to program delivery and meeting community needs.

Anna T. Keegan, Director of Housing Operations - Anna oversees the work of HCV inspectors and occupancy specialists, public housing occupancy specialists, and operations of NHA's ROSS and FSS Programs and Envision Center. An attorney with 10 years of experience in housing, ADA and civil rights law, Anna previously served as the City of Norwalk Civil Rights & Fair Rent Investigator and then as Director of the City of Norwalk Human Relations and Fair Rent Department.  From this work, Anna became familiar with the Norwalk rental market and local resources available to assist residents.

iii.  Statement of Fair Housing, Civil Rights Goals and Strategies

The Norwalk Housing Authority certifies that it will administer all programs and actions in conformity with Title VI of the Civil Rights Act of 1964, the Fair Housing Act, section 504 of the Rehabilitation Act of 1973, and title II of the Americans with Disabilities Act of 1990, and will affirmatively further fair housing by examining their programs or proposed programs, identifying any impediments to fair housing choice within those programs, addressing those impediments in a reasonable fashion in view of the resources available and working with local jurisdictions to implement any of the jurisdiction's initiatives to affirmatively further fair housing that require the NHA's involvement and by maintaining records reflecting these analyses and actions.

2.    Plan for Future Community/Resident Engagement

The NHA has approximately 12 members on its Resident Advisory Board (RAB) that meet quarterly. In light of COVID-19, meeting with the residents, community, and stakeholders occurs via video conferencing.  The NHA held one virtual landlord meeting (July 12, 2021 at 6:00 pm) and two virtual resident meetings (August 18, 2021 and August 26, 2021 at 6:00 pm) as well as a virtual public meeting (September 16, 2021 at 6:00 pm) to discuss the MTW plan and will continue to meet with interested residents and community partners throughout the demonstration.  Translators were and continue to be available to residents as needed.  The NHA will continue to discuss MTW initiatives in regular community meetings, including with landlords at annual landlord meeting(s).  Discussions include addressing issues facing the low-income clientele in the Norwalk community that we serve collectively, including the ability for families to locate units in a challenging market, but especially in low poverty/minority concentration areas.

3.    PHA Operating and Inventory Information

i. Current Inventory

The NHA manages approximately 806 public housing units and has 1,046 HCV's under its Annual Contributions Contract (ACC).  NHA experiences little difficulty in leasing public housing units.  In the HCV program, families do experience difficulties locating units in higher opportunity areas. In the HCV program, units types under assisted lease are as follows:

·       35.5%   Semi-detached

·       29.7% Row House

·       17.5%   High Rise

·        9.6%   Low Rise

·        7.5%   Single family dwellings

NHA's public housing stock is comprised of a mixture of low-rise, high-rise and townhouses.

Household  Demographics

	% Female/Male	% Families  with Children	Disabled/Non-Disabled	White/Afro-American/Asian	Hispanic/Non-Hispanic
HCV	85%/15%	44%	30%/70%	49%/50%/<1%	33%/67%
PH	75%/25%	35%	18%/82%	53%/46%/<1%	42%/58%

ii.  Anticipated changes to demographics of households served

Although the NHA does not expect a significant change to demographics of households served in terms of age, disabilities, ethnicity, etc., the opportunities made available to all families will change considerably. Families will be better able to lease in areas of higher opportunities. In addition, the MTW initiatives will provide families with better educational and employment opportunities, improved access to child care, and public transportation. Adults will have access to better employment opportunities. Seniors and disabled individuals will have access to better medical care options and services.

iii. NHA Major Plans for Housing Stock

Soundview Landing is a 273 unit, mixed-income development with 136 replacement public housing units. Constructed in phases, replacement units include designated supportive housing units, project-based voucher units, LIHTC, and market rate units. Soundview Landing does increase housing opportunities for voucher holders. In addition, under this cohort, voucher holders will be more likely to afford leasing single-family dwellings.

iv. Challenges NHA faces in occupying public housing units, leasing HCV units, and/or serving the special needs of specific populations

Low-income families with children traditionally face challenges in locating units in low poverty areas.  The NHA hopes that through the combination of offered landlord incentives, families can overcome some of these barriers to finding adequate housing despite the rapidly increasing housing costs in the community. 

 v.  Experience and Demonstrated Innovation and Creativity with Other Grants and HUD Programs

The NHA has a long-term goal of ensuring safe and economically viable communities for its residents, using grants and HUD programs to create innovative solutions in addressing family needs and obstacles.  

· NHA continues its long-standing Norwalk Housing Foundation (NHF) college scholarship program for NHA students.

· Due to NHA's having being granted status by HUD as an EnVision Center, NHA's HUD-assisted families now have access to support services that can help them achieve self-sufficiency. 

· Partially funded through grants, NHA's pioneering Learning Centers have long been and continue to be committed to providing NHA students with academic support, enrichment programs, school and career guidance, character building opportunities, and educational field trips.

· Utilizing state funding, NHA's commodities program works to improve the health of low-income elderly persons 60 years of age or older by supplementing their diets with nutritious USDA foods. From April 1, 2020 through March 31, 2021, 910 boxes of food (30,030 pounds) were distributed to Public Housing and Housing Choice Voucher residents. 

· NHA also utilized a one-time Housing Authority Small Improvement Program (HASIP) grant (sponsored by Connecticut Housing Finance Authority) to provide families with PPE, household necessities, and other essentials during the COVID-19 quarantine.

Additionally, the NHA has demonstrated capacity implementing special purpose vouchers allocated by HUD, administering the following special programs:

•  Veteran's Affairs Supportive Housing (VASH) - NHA has been awarded 23 vouchers to house homeless veterans and has a dedicated staff person who meets with the Veteran's Administration staff regularly.
• Mainstream Vouchers - NHA has Memorandums of Understanding (MOUs) with the Family and Children's Agency, the Norwalk Continuum of Care (CoC), and other service providers to serve 100 disabled families.
• Family Unification Program (FUP) - The NHA administers the FUP program with the allocated 7 vouchers fully utilized. Congregate Housing - This state program assists the elderly and frail, and provides housing and special services such as meals and medical support.
• FSS and ROSS: As of March 31, 2021, NHA's self-sufficiency programs have served 158 self-sufficiency participants in the public housing and HCV programs: 105 FSS participants and 53 ROSS participants.

Through the FSS and ROSS programs, NHA has introduced:  

1. Job Training Referral/Employment Referral and Job Fairs;

   2. Health Career Academy;

   3. One-on-One Credit Counseling;

   4. One-on-One Homeownership Counseling;

   5.  HUD's First-Time Home Buying Workshop;

   6.  Health and Wellness Workshops;

   7.  Health Fairs;

   8.  Financial Workshops; and Naturalization and Citizenship Information Sessions.

NHA has utilized HCV program flexibilities to maximize family housing opportunities:

·       HCV Homeownership Program - NHA has 15 homeowners, having entered into successful partnerships with banks and financial institutions in the Norwalk area who provide mortgages and financial management training.

·       Project-Based Vouchers (PBV) - The NHA is the contract administrator for 174 project-based voucher units across multiple developments; all located in low-poverty opportunity area(s). 

·       Tiered Payment Standards - NHA implemented tiered payment standards in the HCV program to increase opportunities for families to lease in higher cost/opportunity areas.

 4.    Plan for NHA Local MTW Program
NHA is seeking to implement landlord incentive activities that address core MTW goals:

Cost Effectiveness

The NHA hopes to reduce annual administrative costs through the ability to establish higher payment standards. Higher payment standards as allowed under the MTW Landlord cohort #4 option 2.b. Payment Standards - Fair Market Rents (FMR) will reduce the number of tenancy requests that are denied, which in turn reduces the need for NHA to reissue vouchers and leasing paperwork to families.

Self-Sufficiency for Residents

The NHA has for years focused on four pillars chosen to support family self-sufficiency: (1) Economic Empowerment, (2) Educational Advancement, (3) Health and Wellness, and (4) Character and Leadership. The increased ability for families to lease up in higher opportunity areas through the NHA's ability to establish payment standards at up to 150% of FMR under MTW Landlord cohort #4 option 2.b. Payment Standards - Fair Market Rents (FMR) improves opportunities for education, job training, employment, medical treatment, and child care. Better access to transportation, job training, employment and child care will increase the family's ability to maximize benefits of the FSS program, and will assist in family members being able to acquire and retain higher paying employment positions. Increased access to educational opportunities will have long term impacts on children, which will help break the cycle of poverty.

Housing Choice

The ability for NHA to raise its payment standards under MTW Landlord Cohort #4 option 2.b. Payment Standards - Fair Market Rents (FMR) will support NHA's efforts to encourage families with and without children to move to opportunity areas throughout the Norwalk community. 

The other selected landlord initiatives chosen under MTW Landlord cohort #4 (4.a. Vacancy Loss payments, and 4.b. Damage claim payments) each carry additional benefits supporting family choice in units. Both options support and promote landlord participation in all areas of the community. Both initiatives encourage owners to complete unit repairs and upgrades, resulting in overall improved housing stock. In owner meetings, owners shared that NHA's implementation of the vacancy lost payment initiative would also result in owners being likely to 'hold' a unit for a voucher holder then to lease immediately to a non-voucher holder.

All MTW cohort 4 actions selected focus on helping families successfully move into homeownership and achieve housing stability in low poverty areas.

The three specific initiatives to be implemented by NHA are:

  2.b. Payment Standards - Fair Market Rents (FMR): The ability for the PHA to establish payment standards between 80% and 150% of the HUD-published FMR.

  4.a. Vacancy Loss: The ability for the PHA to pay landlords up to one-month contract rent as reimbursement for time the unit spends vacant between HCV participants.

 4.b. Damage Claims: The ability for the PHA to reimburse landlords for tenant-caused damages (minus security deposit) up to two months contract rent after tenancy.

5.    Proposed Use of MTW Funds
The NHA is formally requesting flexible use of HCV funds in the MTW demonstration program.

i. Proposed Use of MTW fund flexibility
The NHA intends to use HCV funds flexibly across the traditional Section 8 through:

- Under Landlord cohort #4 2.b. Payment Standards - Fair Market Rents (FMR) Initiative: The ability for the PHA to pay Housing Assistance Payments (HAP) based on payment standards established between 80% and 150% of the HUD-published FMR (versus between 90% and 110% per regulation).

- Under Landlord cohort #4 4.a. Vacancy Loss Initiative: The ability for the PHA to utilize HCV funds to pay landlords up to one-month contract rent as reimbursement for time the unit spends vacant between HCV participants (not currently authorized in regulations).

- Under Landlord cohort #4 4.b. Damage Claims Initiative:  The ability for the PHA to utilize HCV funds to reimburse landlords for tenant-caused damages (minus security deposit) for up to two months contract rent after tenancy. 

6.    Evidence of Significant Partnerships

NHA's many community partnerships were tested by COVID-19 and the related quarantine. Outcomes of working with these partners proved the strength of the relationships. NHA coordinated efforts between Senior Services, the City of Norwalk, Community Health Centers, and Food Banks to provide food, masks, information, and services to quarantined individuals and families in the community. Services included well-being checks and free COVID-19 testing. 

NHA collaborates with the Norwalk Early Childhood Council to help NHA families with kindergarten registration. Partners include:  

o   Norwalk ACTS

o   Connecticut Afterschool Network

o   The National Afterschool Association

o   Norwalk Public Schools

o   Silvermine Arts Center

o   Stepping Stones Museum for Children

o   Norwalk Office of Early Childhood

o   Norwalk Health Department

o   Literacy HOW, Inc.

o   H.E.L.P., Inc.

o   Velo-CT

o   Norwalk Reads

NHA Manages Properties for Mutual Housing through NHA's Sound Communities. Sound Communities is a developer and manager of mixed income housing; its mission is to expand and preserve mixed communities.

NHA continues to identify new local partners in order to partner and collaborate with more local social service agencies, and continues to deepen the existing partnership with the City of Norwalk and the Board of Education in order to expand upon the existing services and offerings available to families.  

B.    LANDLORD INCENTIVE ACTIVITIES INFORMATION

1.   Landlord Needs Assessment
 Norwalk is a medium sized community, located near New York City. Significant development of large housing complexes has increased rental costs in areas that were traditionally more affordable. Due to COVID, rents have skyrocketed, resulting in more New York residents seeking to rent in Norwalk and its neighboring communities.

Landlords and families cited high rents in the community as a significant barrier to HCV holders seeking to lease in Norwalk. Some landlords also hold the perception that Section 8 tenants are more likely to leave with unit damages. Landlords also state that timing the move-in of voucher holders can be challenging, given the actions that must be completed by NHA before the assisted tenancy may be approved.  

2.   MTW Cohort 4 Activities
The Norwalk Housing Authority has selected the following MTW activities under Cohort 4:

 2.b. Payment Standards - Fair Market Rents (FMR):

In the HCV program, if the family rents a unit with a gross rent that is higher than the Payment Standard, the family must pay the difference and this amount is added to the tenant rent to owner.  24 CFR 982.305(a)(5) states that at initial occupancy the PHA may not approve the tenancy if it would require the family share to exceed 40 percent of the family's monthly adjusted income.

24 CFR 982.503(b) requires that the PHA establish a payment standard within a "basic range" established by HUD - between 90 and 110 percent of the published FMR for each unit size.

The ability for the NHA to establish Payment Standards between 80% and 150% of the FMR will support PHA leasing efforts as NHA will be able to establish higher Payment Standards in higher rent areas, making a broader range of units available to voucher holders. This will address landlord and homeless advocate concerns regarding rents being too high for the PHA to approve (per 24 CFR 982.305(a)(5)), and will provide families with the ability to lease units in areas outside of high poverty/minority concentration. This should result in improved economic outcomes for low-income families.

4.a. Vacancy Loss:

The ability for NHA to pay landlords up to one-month contract rent as reimbursement for time the unit spends vacant between HCV participants not only promotes and supports landlord participation in all areas of the community, but encourages owners to complete unit repairs and upgrades, resulting in overall improved housing stock. In addition, owners are more likely to 'hold' a unit for a voucher holder pending the HQS inspection and/or other necessary actions then to lease immediately to a non-voucher holder.

4.b. Damage Claims:

The ability for NHA to reimburse landlords for tenant-caused damages (minus security deposit) up to two months contract rent relieves stated owner concerns and perceptions regarding unit condition after tenancy. Although the fears that voucher holders are more likely to damage units is usually groundless, this policy promotes participation by new landlords by giving a concrete way to alleviate concerns of property damage while allowing owners to experience first-hand the positive experience of leasing to assisted low-income families. This action encourages moves to higher opportunity areas and increases housing choice.

 2.   Other Landlord Incentives and Initiatives

Although the NHA is not requesting waivers under this initiative, the NHA has other current landlord incentives and initiatives in place that encourage participation by new owners and support existing owners. These include but are not limited to:

- In 2007, the NHA enacted a two-tiered payment standard for the Housing Choice Voucher program. The two-tiered approach in payment standards supports higher rent payments in low-poverty census tracts, thus encouraging families to locate units in opportunity zones.

- The NHA holds yearly landlord meetings in conjunction with the City's Fair Rent and Fair Housing staff to educate landlords on local housing law and the HCV program, and give landlords an opportunity to meet the NHA staff and ask questions about the program

- The NHA Landlord Handbook is available to anyone through NHA's website.

- Additional HCV tools and resources are available to owners on NHA's website, including:

o   FAQs

o   Key forms

o   Link to Gosection8.com, where an owner may list units available for rent

- Landlord Portal: when visiting NHA's the website, landlords may link to HMS PAL™ (Payment Access for Landlords).  Landlords receiving Housing Assistance Payments (HAP) may look up payment history, turn on email notifications of payments, check for the most recent payment, etc.