A Review of Work

Requirement Polic

ies

in HUD-Funded

Assisted Housing

Final Research Report

U.S. Department of Housing and Urban Development | Office of Policy Development and Research

DISCLAIMER

The contents of this report are the views of the author and do not necessarily reflect the views or policies of the U.S. Department of Housing and Urban Development or the U.S. Government.

A Review of Work Requirement Policies in HUD-Funded Assisted Housing

FINAL RESEARCH REPORT

Prepared for:

U.S. Department of Housing and Urban Development

Office of Policy Development and Research

Prepared by:

Hiren Nisar

Maxwell Matite

Lan Hu

2M Research

June 10, 2022

FOREWORD

Moving to Work (MTW) is a demonstration program for public housing agencies (PHAs) that allows them the opportunity to work outside the normal HUD housing assistance rules in order to design and test innovative, locally developed alternative strategies for the delivery of housing assistance. These innovative strategies are designed to achieve one or more of the following statutory goals: use federal dollars more efficiently, help residents find employment and become self-sufficient, and increase housing choices for low-income families.

Since the inception of the MTW program in 1996, 9 of the 39 initial MTW PHAs have used their

flexibilities to implement work requirement policies in their assisted housing programs, and as of 2022, only 7 MTW agencies still had a work requirement policy in place. Work requirement policies

essentially impose requirements on assisted households to engage in either employment or employment-related activities to maintain eligibility for their housing assistance. The policies that have been implemented by the MTW PHAs vary widely in their requirements, target population, and monitoring and compliance procedures. To date, very little rigorous research and a modest number of descriptive studies have been conducted on the outcomes of work requirement policies in assisted housing.

In 2016, Congress directed HUD to expand the MTW demonstration by an additional 100 agencies, thus providing an additional set of PHAs with the opportunity to implement a work requirement policy, should they choose to do so. HUD’s Office of Policy Development and Research (PD&R) sponsored this study to document the experience of the few PHAs that have implemented work requirements using MTW flexibilities, gather the perspectives of industry and advocacy group leaders on this topic, and summarize the research on the outcomes of work requirement policies in other similar public benefit programs.

Literature documenting outcomes of work requirement policies in other federal government programs reveal few, if any, beneficial outcomes and several negative outcomes for program participants. For example, studies of the work requirement policy in TANF [Temporary Assistance for Needy Families], which provides cash assistance to needy families, indicate that it has failed to help families achieve financial independence and led to a rise in deep poverty. Similarly, research on the work requirements in SNAP [Supplemental Nutrition Assistance Program], the nation’s largest antihunger program, found that the policy has had no positive impact on employment and led to reduced participation in the program, contributing to negative public health impacts due to the lack of food access.

Less is known about work requirements in HUD-assisted housing. This report elevates the perspectives of expert stakeholders and industry leaders in the housing policy community and presents case studies of the nine MTW PHAs that implemented work requirements.

HUD is committed to implementing the MTW expansion in a way that is responsive to the economic realities and needs of low-income families and decided to stop seeking applicants for the MTW cohort on work requirements in June 2021. Although HUD rescinded the MTW expansion cohort, MTW

ii

expansion agencies have the option to implement work requirements. We hope that MTW agencies

considering implementing a work requirement policy will find this report useful.

Solomon J. Greene

Principal Deputy Assistant Secretary for Policy Development and Research

U.S. Department of Housing and Urban Development

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

TABLE OF CONTENTS

1. Introduction .......................................................................................................................................... 1

Study Approach to Addressing the Research Objective .................................................................................. 2

2. Literature Review ................................................................................................................................. 5

Temporary Assistance for Needy Families ....................................................................................................... 5

Supplemental Nutrition Assistance Program ................................................................................................... 8

Medicaid ............................................................................................................................................................ 10

Housing Assistance ............................................................................................................................................ 13

3. Findings from Key Stakeholder Interviews ..................................................................................... 16

Designing a Work Requirement Policy for HUD-Funded Assisted Housing ............................................... 16

Implementation and Monitoring of a Work Requirement Policy for HUD-Funded Assisted Housing .... 19

Desired Outcomes of a Work Requirement Policy in HUD-Funded Assisted Housing .............................. 21

4. Case Studies Synthesis and Key Findings ........................................................................................ 23

Overview of Nine PHAs and Their Work Requirement Policies .................................................................. 23

Development of a Work Requirement Policy ................................................................................................. 28

Implementation of a Work Requirement Policy ............................................................................................ 30

5. Conclusion ........................................................................................................................................... 38

Appendix A: Details of Literature Review .............................................................................................. 40

Appendix B: Case Studies of MTW PHAs With a Work Requirement ............................................... 44

References ................................................................................................................................................ 123

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

1. INTRODUCTION

In 2020, nearly 4.6 million households received

MTW PHAs that have implemented work

housing assistance from the U.S. Department of

requirements:

Housing and Urban Development (HUD) through



Atlanta Housing

tenant-based vouchers, project-based subsidies, and



Housing Authority of Champaign County

the provision of public housing (HUD, n.d.). Those



INLIVIAN (formerly Charlotte Housing

subsidies are intended to aid low-income families

Authority)

and individuals in finding safe, decent, and



Chicago Housing Authority

affordable housing and to potentially meet their



Delaware State Housing Authority



Lawrence-Douglas County Housing

individual goals related to employment and asset

Authority

building. Starting in the late 1990s, Congress has



Lexington-Fayette Urban County Housing

enacted laws that incorporate work requirements into

Authority

several federal public benefit programs, including



Louisville Metro Housing Authority (sunset

the Temporary Assistance for Needy Families

in 2017)

(TANF) program and the Supplemental Nutrition



Housing Authority of the County of San

Assistance Program (SNAP). Recently, several states

Bernardino (sunset in 2019)

adopted similar work requirement policies for

individuals receiving Medicaid. Over time, various

legislative proposals related to housing policy have included the option to implement work requirement policies for individuals and families who received HUD-assisted housing, but none of those proposals have become law.

In 1996, Congress authorized the Moving to Work (MTW) demonstration to give public housing agencies (PHAs) greater flexibility in how they provide housing assistance to achieve one or more statutory objectives: to reduce costs and achieve greater cost-effectiveness in federal expenditures; to provide incentives to families with children, in which the head of household is working, seeking work, or preparing for work; and to increase housing choices for low-income families. As of December 15, 2015, 39 PHAs had an active MTW agreement under the original 1996 authorization; those PHAs are referred to as initial MTW agencies. In 2016, Congress directed HUD to expand the MTW demonstration program from the 39 initial MTW agencies by an additional 100 agencies. As of March 2022, 109 PHAs have been designated as MTW agencies.

MTW agencies have the authority to implement a work requirement policy in either the Housing Choice Voucher (HCV) or the public housing program. Nine of the initial 39 MTW agencies have implemented a work requirement policy at some point since their designation as an MTW agency, and as of 2022, 7

MTW agencies still had a work requirement policy in place. 1 Aside from one study of the impact of work requirements at INLIVIAN (Rohe, Webb, and Frescoln, 2015), limited rigorous evidence exists regarding the impact of work requirement policies in assisted housing. The initial MTW PHAs submit annual MTW

1 Each of the MTW PHAs went through a 30-day public review process, as detailed in their MTW Standard Agreement, to inform the community of this programmatic change; conducted outreach to encourage participation; and gave the public an opportunity to comment on the implementation of the program.

.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Plans and Reports that provide descriptive analyses on all of their MTW policies, including work requirements.

HUD supported this research effort to explore what could be learned about the implementation and outcomes of work requirement policies by studying the initial MTW agencies that have chosen to implement a work requirement policy at some point in time. Specifically, this study has three components:

1. A literature review focusing on work requirement policies in select public benefit programs, including assisted housing.

2. A series of interviews with a range of industry and advocacy groups and researchers to gather their perspectives on work requirement policies in HUD-funded assisted housing.

3. Semi-structured interviews with the nine initial MTW agencies that have ever implemented a work requirement policy.

Data collection and analysis for this study focused on the nine initial MTW agencies that have ever implemented a work requirement policy and is built on the developmental research conducted by HUD in October 2018.

Study Approach to Addressing the Research Objective

Exhibit 1 presents the study team’s approach to each of the three study components. The first step was to conduct a systematic literature review (component 1) focused on work requirement policies in four public benefits programs: SNAP, TANF, Medicaid, and HUD-assisted housing. Simultaneously, in consultation with HUD, the authors conducted interviews with eight industry and advocacy group experts and researchers to collect their perspectives on work requirements (component 2) and with key stakeholders at each of the nine initial MTW agencies that have implemented a work requirement policy (component 3).

Exhibit 1. The Team’s Mixed-Methods Design

Components

Procedures

1. Literature Review

• Conduct systematic literature review of published articles and reports

on selected programs with work requirements.

• Develop interview protocol.

2. Expert Interviews

• Select 12 key experts for interviews.

• Interview eight experts from industry or advocacy groups and

researchers.

• Develop interview protocol.

• Review key documents (MTW plans, website review, and other public

3. MTW PHA Interviews

information published regarding their work requirement policy).

• Conduct nine interviews with staff from the MTW PHAs with work

requirements (one per PHA).

Component 1: Literature Review

Under component 1 of this study, the study team conducted a comprehensive literature review of research on work requirements that have been established in four public benefit programs—SNAP, Medicaid, TANF, and housing assistance—by summarizing the peer-reviewed literature and any state and federal government reports that have documented or evaluated work requirement policies in each public benefit program identified. This literature review focused on research efforts that have documented the work 2

A Review of Work Requirement Policies in HUD-Funded Assisted Housing

requirement policy, how the policy is implemented and enforced, and any available impact or outcomes data related to the work requirement policy. The findings from this literature review contribute to a foundational understanding of how public benefit programs implement work requirements; the findings also highlight key gaps in the existing knowledge base.

Reviewing and Screening Identified Literature

After conducting the initial searches on databases that store peer-reviewed literature and searching the web, the study team systematically documented the relevant literature for review and flagged any references in those articles for review. When the title or abstract met the inclusion criteria (see exhibit A.3

in appendix A), the authors flagged the study for a full-text review. For comprehensiveness, during the screening process, the team reviewed the literature not only for mentions of the selected programs of interest but also for mentions of work requirements in the relevant programs. For articles or reports that met the criteria for a full-text review, the authors extracted the following information, when available, for inclusion in the literature review.

 Citation

 Work requirement

 Included program(s)

 Main theme

 Data source(s)

 Study design and methods

 Unit of analysis

 Included variables

 Population (and subpopulations of interest—

 Findings

for example, race and ethnicity, gender,

 Study implications

income, geography, and other community

 Suggestions for future research

characteristics)

Summarizing, Synthesizing, and Interpreting the Final Literature

Using the review process described in appendix A, the team identified common themes in the literature regarding work requirement policies, areas of concurrence or disagreement, and knowledge gaps. The Literature Review chapter in this report synthesizes the information from more than 50 articles and reports that provide a foundational understanding of the implementation of work requirements in public benefit programs and available outcomes and impacts that have been documented. For details on the methods used for the literature review, please see appendix A.

Component 2: Semi-Structured Interviews

with Key Stakeholders

Interview Guide Domains for Key

Stakeholders

For this component, the study team conducted 60-

minute semi-structured interviews with eight key



Goal of a Work Requirement

stakeholders—experts and industry leaders in



Development of a Work Requirement Policy

o Inclusion/Exclusion Criteria for

housing policy—identified by HUD. The interview

Participants

data were analyzed using qualitative methods to



Implementation of the Work Requirement

identify key themes. Those themes are presented in

o Length of Phase-in Period

the Findings from Key Stakeholder Interviews

o Potential Barriers and Supportive

chapter in this report. Those interviews provide

Services to Overcome Those

information on each organization’s perspective on

Barriers

work requirement policies in assisted housing and

o Monitoring Compliance and

any intended outcomes from the work requirement

Sanctions for Noncompliance

policy.



Assessment of a Work Requirement Policy

o Desired Outcomes

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Key Stakeholder List



Angela Rachidi, Senior Fellow and Rowe Scholar in Poverty Studies, American Enterprise Institute



Deborah Thorpe, Deputy Director, National Housing Law Project



Diane Levy, Principal Research Associate, Metropolitan Housing and Communities Policy Center at Urban Institute



Georgi Banna, Former Director of Policy and Program Development, previously at the National Association of Housing and Redevelopment Officials



Michael Webb, Managing Associate, Community Science



Nicole Barrett, MTW Program Manager, MTW Collaborative



Tim Kaiser, Executive Director, Public Housing Authorities Directors Association



Will Fischer, Senior Director for Housing Policy and Research, Center for Budget and Policy Priorities Component 3: Semi-Structured Interviews with MTW PHA Staff

Component 3 consisted of administering a 60-

Interview Guide Domains for PHA Staff

minute semi-structured interview guide2 to staff

from the nine initial MTW agencies that have ever



Motivation for Work Requirement Policy

implemented a work requirement policy. The



Intended Benefits and Desired Outcomes

interviews covered the motivations behind pursuing



Implementation of the Work Requirement,

Including Compliance and Sanctions for

a work requirement policy; perceived benefits and

Noncompliance

desired outcomes from the policy; details on how



Perceived Outcomes

the policy was implemented, monitored for



Inclusion/Exclusion Criteria for Participants

compliance, and enforced for noncompliance; any



Successes and Challenges of the Program

documentation of outcomes from the policy; any



Recommendations for Improvement,

modification to the requirement during the COVID-

Expansion, and Sustainability to Better Serve

19 pandemic; any challenges faced and lessons

HUD-Assisted Households

learned during implementation; and

recommendations for other MTW agencies that

might be considering implementation of a work requirement policy. The PHA interviews provided information that could not be found in existing literature or program documents. Each MTW PHA profile includes standard elements representing the domains established in the interview guide and, as appropriate, integrated data abstracted from the literature review, data abstracted from PHA websites, a review of existing documents (such as MTW PHA plans, transcripts from previous interviews, and articles obtained during the literature review search), any relevant program or policy reports provided to the study team by HUD, and program data. After developing the program profile, the team provided the MTW PHA profile to respective program staff for review to ensure accuracy before the interview.

After the data collection phase ended, the team

In qualitative research, themes are patterns across

developed a case study for each PHA, updating the

datasets that are important to the description of a

program profile using the interview data and using

particular phenomenon and are associated with a

the guide domains as a template. This final case

specific research question.

study was also sent to the PHA for review before

finalizing.

2 Where available, the study team updated the Master Interview Guides through the background research conducted on each stakeholder and each MTW PHA program.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

2. LITERATURE REVIEW

In the late 1990s, Congress began enacting laws that incorporated work requirements into several federal public benefit programs, including the Temporary Assistance for Needy Families (TANF) program and the Supplemental Nutrition Assistance Program (SNAP). Recently, several states adopted similar work requirement policies for individuals receiving Medicaid. This chapter provides a foundational understanding of the implementation of work requirements in those select public benefit programs and any outcomes or impacts of those policies that have been documented.

Temporary Assistance for Needy Families

Overview of TANF’s Work Requirement Policy.

TANF provides cash assistance to needy families

TANF

with children to help them achieve economic self-

TANF is designed to help low-income families with

sufficiency. States can set their own policies

children with financial assistance and employment-related

regarding who is required to participate in work

support services for up to 60 months. Each state has some

activities and which activities “count” as work

flexibility in operating the program.

activities. To maintain cash benefits, adults in

Eligibility: Participants are U.S. citizens or

families are generally required to participate in

legal/qualified aliens who are residents of the state and

work activities for a certain number of hours per

who are pregnant or have a child.

week depending on the number of work-eligible

Work Requirement Policy: All adults in families that

adults and the ages of children in their family. For

receive TANF benefits are required to participate in work-

example, single parents with a child younger than

related activities. Adults who have a documented

age 6 are required to work at least 20 hours per

disability, are pregnant, or have recently given birth can

be temporarily exempted from the work requirements.

week, whereas two parents with young children

are required to work at least 35 hours per week if

Desired Outcome of the Policy: Increase self-sufficiency

the family is not receiving subsidized childcare or

of program participants and reduce their dependence on

government benefits.

55 hours per week if the family is receiving

subsidized childcare (Hahn et al., 2017).

Activities That Count Toward Work Requirement:

Participants can engage in any of nine core

•

Core activities:

activities to satisfy the work requirement; TANF

o Unsubsidized employment.

o Subsidized private sector job

also has three supplemental activities individuals

o Subsidized public sector job

can engage in after completing 20 hours per week

o Job search and job readiness

of core activities. Federally funded TANF benefits

o Community service

are restricted to not more than 60 months for each

o Work experience

family (Center on Budget and Policy Priorities,

o On-the-job training

o Vocational educational training

2022). The work requirement component of the

o Caring for a child of a recipient

TANF program is the most rigorously evaluated

•

Supplemental activities:

work requirement policy across the set of federal

o Job skills training

benefit programs in which such a policy has been

o Education related to employment

o Completion of secondary school

implemented.

Federal Standards for Compliance: States engage more

Sanctions for Noncompliance. Sanctions are

than 50 percent of cash assistance recipients with one

imposed on families that fail to meet the

work-eligible adult and 90 percent of families with two

requirements without “good cause.” Although

work-eligible adults in work activities for a minimum

each state may determine its own penalty policy,

number of work hours.

nearly all states choose to terminate benefits to

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

entire families who are noncompliant. However, states’ decisions are substantially affected by the federal work participation standards that penalize states by a reduction in TANF grant funding if they fall out of compliance (Falk, 2011). States also receive “caseload reduction credit” toward meeting the federal requirements if they have had a decrease in families on TANF since 2005, as most states meet their federal work compliance rates.

Impact and Success of the Work Requirement Policy. The body of literature evaluating the impact of the work requirement feature of the TANF program is robust and includes numerous rigorous impact studies.

Studies of TANF’s work requirement policy indicate that it has not been effective in assisting families to achieve financial independence, as designed (Hahn, 2018; Pavetti, 2018; Pavetti and Zane, 2021), for the following reasons:

 The TANF work requirement policy led to a rise in deep poverty. TANF work requirements led to modest employment increases, but most TANF benefit recipients remained in poverty

because the initial employment gain tended to decrease over time (Pavetti, 2016). According to Trisi and Saenz (2020), the deep poverty (income below 50 percent of the federal poverty line) ratio among children in single-mother families, who are one of the target beneficiaries of TANF, had increased from 5.4 percent to 7.4 percent from 1995 to 2005 (one decade after the restrictive TANF program was created in 1996). Mitchell, Pavetti, and Huang (2018) found that 40 percent

of parents had no earnings, and another 30 percent had earnings below the deep-poverty level in the fourth year after leaving TANF because of noncompliance sanctions.

 The TANF work requirement policy did not help welfare recipients secure and retain stable jobs. Because of low educational attainment or limited work experience, lack of childcare, or lack of transportation, many parents who received TANF assistance found securing and maintaining

employment difficult. Although studies (for example, Zane and Pavetti, 2020) showed that at least 60 percent of TANF recipients were able to secure jobs during the first year after leaving the program, few worked steadily throughout that year, and the jobs tended to have high income

volatility and turnover. For families with work-eligible adults whose TANF benefits were

terminated due to noncompliance with the work requirement, employment rates tended to be

lower compared with employment rates than families in which the parents exited TANF for other reasons (Lee, Slack, and Lewis, 2004).

Assessment of the Work Requirement Policy. The literature reviewed also indicated that the TANF work requirement policy produced other negative impacts, which are summarized below.

 The TANF work requirement policy caused a decline in TANF welfare coverage. Bentele and Nicoli (2012) observed a decline in TANF welfare coverage from 1995 to 2009, and they argued

that with the strict work requirement policy, assistance recipients either found and were covered by other types of financial support (for example, SNAP) (Grogger, Karoly, and Klerman, 2002) or were terminated from TANF because of noncompliance with the work requirement (Falk,

McCarty, and Aussenberg, 2014).

 The TANF work requirement policy decreased the share of nonparticipants who reported

wanting to work. Barnichon and Figura (2016) found a decreasing share of nonparticipants (who were previously participating in TANF) who reported wanting to work, as the strict TANF work

requirement policy pushed the recipients who were least able to find work out of the program.

 The TANF work requirement policy contributed to restrictive childcare subsidies. Ha and Ybarra (2013) observed that states strictly implementing the TANF work requirement policy were likely to have restrictive income eligibility rules for childcare subsidies, implying that childcare 6

A Review of Work Requirement Policies in HUD-Funded Assisted Housing

assistance amounts might be insufficient in states that enforced the work requirement policy

stringently.

 The TANF work requirement policy did not have positive impacts on child well-being. Wang (2015) found that stringent TANF policies did not positively affect children’s well-being.

Children were more likely to repeat a grade, parents were less likely to praise children or engage them in fun activities, and parents tended to spend less time reading to or with children in states with stricter adherence to TANF policies than in states with more lenient approaches to TANF

policies.

Summary

TANF was designed to help needy families with children achieve self-sufficiency by providing financial assistance and connecting parents to work. However, research regarding TANF suggests that the work requirement policy failed to lift the families out of poverty or help them gain and retain employment. A review of the literature also revealed that the work requirement policy caused several negative outcomes for families. To improve the effectiveness of the current policy, Schott and Pavetti (2013) proposed the following changes for policymakers to choose from to improve the effectiveness of TANF’s work requirement policy.

 Redesign work requirements to engage recipients in a broader range of activities. Changes such as (1) allowing a wider range of work activities, including those addressing serious barriers to employment, and (2) removing limits on some activities, including job training and vocational education, could be incorporated into the current work requirement policy.

 Place more emphasis on employment outcomes instead of engaging in work activities.

Consider replacing assessment standards with employment-based measures that evaluate whether

parents successfully secure employment after they exit TANF benefits. That change could

encourage states to focus more on improving employment placement by giving more credits to

states for successful employment placements and fewer credits for engaging participants in work activities.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Supplemental Nutrition Assistance

SNAP

Program

SNAP aims to improve food purchasing power for

Overview of SNAP’s Work Requirement Policy.

eligible low-income households to improve their

SNAP is the nation’s largest antihunger program,

nutrition and reduce hunger and malnutrition. The

federal government pays all benefits and splits the

providing food support to supplement the food

administration cost with states that operate the program.

budget of needy, low-income families so they can

purchase healthy food and move toward self-

Eligibility:

•

A household’s gross monthly income must be at

sufficiency (USDA, 2018). SNAP has two sets of

or below 130 percent of the federal poverty line.

work requirements:

•

A household’s income minus allowable

deductions must be at or below 100 percent of the

 General work requirements for program

federal poverty line.

participants ages 16 through 59 who are able to

•

A household with elderly members or members

work. They are required to register for work,

with a disability have slightly different income

participate in SNAP Employment and Training

limits.

(E&T) or workfare, or take a suitable job.

Exceptions/Excused:

 Additional work requirements for “able-bodied

•

Working at least 30 hours a week

adults without dependents” (ABAWD) ages 18

•

Meeting work requirements for another program

(such as TANF or unemployment)

through 49. They are required to meet both the

•

Taking care of a child younger than age 6 or an

general and ABAWD work requirements to

incapacitated person

receive SNAP for more than 3 months in a 3-year

•

Having a physical or mental limitation

period. ABAWDs need to work or participate in a

•

Participating in an alcohol or drug treatment

work program at least 80 hours a month to be

program

•

considered compliant (USDA, 2019).

Studying in school or a training program at least

half-time

Sanctions for Noncompliance. If recipients fall out

Work Requirement Policy: Work-able adults ages 16

of compliance with the general work requirement,

through 59 are required to meet SNAP work requirements.

they are disqualified from receiving SNAP for at

Desired Outcome of the Policy: Improve food

least 1 month. If recipients reenroll in SNAP and fail

security and health

to meet the requirements again, disqualification

Activities that Count Toward Work Requirement:

from receiving SNAP could be longer than 1 month

•

General work requirements:

or even permanent.

o SNAP E&T or workfare

o Employment

For noncompliance with ABAWD work

•

ABAWD work requirements:

requirements, recipients are disqualified from

o Employment

benefits after 3 months of benefit receipt.

o Work program or workfare.

Individuals must meet the work requirement for a

30-day period or become excused from the work requirement to be eligible for SNAP participation again.

Otherwise, they need to wait until the end of a 3-year period before they can apply to receive another 3

months of benefits (USDA, 2018).

Challenges Implementing Work Requirement Policy. SNAP’s work requirement policy and time limits are complicated to administer, causing errors in determining which recipient’s benefits should be terminated and increasing administrative costs. For example, some states struggled to determine if a beneficiary has a “good reason” to avoid sanctions and found that some recipients who had their benefits taken away actually met exemption criteria (Bolen, Llobrera, and Keith-Jennings, 2021). Moreover, Gehr (2017) argued that because state administrators devoted considerable time tracking work hours and 8

A Review of Work Requirement Policies in HUD-Funded Assisted Housing

documenting compliance with the policy, they had less time and fewer resources to provide effective education and training services or assist beneficiaries reentering the workforce.

Impacts and Successes of Work Requirement Policy. Impacts of SNAP’s work requirement policy have been widely examined in literature. The major findings are summarized below.

Work requirements led to a reduction in SNAP participation. Several studies found that the SNAP work requirement policy caused a large reduction in overall SNAP participation (Gray et al., 2021; Harris, 2021; Ku, Brantley, and Pillai, 2019; Stacy, Scherpf, and Jo, 2018), with nearly 600,000 people losing SNAP benefits from 2013 to 2017, which could lead to negative public health impacts due to the lack of food access (Ku, Brantley, and Pillai, 2019). Moreover, Gray et al. (2021); Stacy, Scherpf, and Jo (2018); and Harris (2021) observed that SNAP work requirements tended to disproportionately screen out people with greater economic vulnerability, including African-American recipients or recipients with low educational attainment.

Work requirements had no positive impact on employment. Although Harris (2021) detected a slight increase in employment caused by SNAP’s work requirement policy, Feng (2021) argued that this increase might also be due in part to a strong economy with sufficient employment opportunities. Several other studies (Cuffey, Beatty, and Mykerezi, 2022; Feng, 2021; Stacy, Scherpf, and Jo, 2018; Wheaton et al., 2021) failed to find an effect of the work requirement on employment. Bolen, Llobrera, and Keith-Jennings (2021) argued that sanctions for noncompliance are not helpful for recipients to gain employment. Taking away SNAP benefits can result in significant hardship because food insecurity and poor health can make finding and sustaining employment more difficult.

Lessons Learned About SNAP Work Requirement Policy. Individuals who apply for SNAP benefits typically live in low-income neighborhoods and have low-paying jobs without paid sick leave, basic benefits, or stability (Keith-Jennings and Chaudhry, 2018), which creates challenges for beneficiaries to remain employed for an extended period and to work the required 20 hours per week to stay eligible for SNAP benefits (Bolen, Llobrera, and Keith-Jennings, 2021). For example, workers can lose their jobs when they are sick or because of transportation barriers, which would put them at risk of being terminated from SNAP benefits under the work requirement policy (Karpman, Hahn, and Gangopadhyaya, 2019).

Stakeholders have also been critical of the 3-month time limit, as it does not consider labor market realities, such as the time required to look for a job (Bolen, Llobrera, and Keith-Jennings, 2021).

Summary

SNAP is designed to provide food support to low-income households. However, the work requirement policy in the program can create barriers to receiving benefits for some eligible households (Gray et al., 2021; Harris, 2021; Ku, Brantley, and Pillai, 2019; Stacy, Scherpf, and Jo, 2018). The policy has also been shown to be ineffective in helping recipients work toward self-sufficiency (Cuffey, Beatty, and Mykerezi, 2022; Feng, 2021; Stacy, Scherpf, and Jo, 2018; Wheaton et al., 2021). Bolen, Llobrera, and Keith-Jennings (2021) proposed the following two changes to make the work requirement policy more effective.

 Focus on connecting SNAP participants to employment opportunities. Instead of forcing participants to engage in required work activities, SNAP’s work requirement policy should shift focus to help participants improve their skill sets through employment training, which may yield better employment outcomes and does not risk taking away benefits from needy families.

 Eliminate the 3-month time limit. As discussed above, the 3-month time limit increases the incidence of food insecurity for families without children. Bolen, Llobrera, and Keith-Jennings (2021) suggested that the additional work requirement applied to ABAWDs should be

permanently eliminated.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Medicaid

Medicaid

Overview of Medicaid’s Work Requirement Policy.

Medicaid is a public insurance program that provides

In 2018, the Centers for Medicare & Medicaid

health coverage to low-income families and

Services (CMS)3 released a letter to state Medicaid

individuals, including children, parents, pregnant

directors outlining how states might implement a

women, seniors, and people with disabilities. Each state

work requirement in the state Medicaid program,

has a great deal of flexibility in designing and

administering its Medicaid program.

also referred to as community services engagement.

Arkansas was the first state to implement a work

Eligibility:

requirement policy in its Medicaid program. 4 The

•

Children through age 18 in families with incomes

specifics of the work requirement policies among

below 133 percent of the federal poverty line.

the 12 states5 that were approved to implement such

•

Women who are pregnant and have incomes

a policy vary by state, with most states requiring

below 133 percent of the federal poverty line.

work-able enrollees to work approximately 20 to 80

•

Certain parents or caretakers with very low

hours per month through qualifying activities to

incomes.

•

Most seniors and people with disabilities.

receive Medicaid benefits (Sommers et al., 2019). In

January 2021, the U.S. Department of Health and

States need to cover the populations above to receive

Human Services (HHS) was directed to review

federal funding, but they may also receive federal

Medicaid funds to cover other optional populations.

waiver policies that may undermine Medicaid, and

CMS subsequently withdrew Medicaid work

Work Requirement Policy: Able-bodied Medicaid

requirement waivers in all states that had approvals. 6

enrollees are required to work approximately 20 hours

per week or 80 hours per month. Children younger than

Sanctions for Noncompliance. Penalties for non-

18 years old, seniors, people who are medically frail or

compliance vary slightly across states. For example,

have a disability, pregnant women, and primary

caregivers are exempted from the work requirements.

in Arkansas, enrollees who fail to comply with the

work requirements for 3 months are disenrolled

Desired Outcome of the Policy: Promote better health

from Medicaid benefits and prohibited from

and help beneficiaries escape poverty.

reenrolling until the following January. In Indiana,

Activities That Count Toward the Work

Kentucky, New Hampshire, and Utah, noncompliant

Requirement:

families were disenrolled but were able to regain

•

Full- or part-time employment

•

Medicaid coverage as soon as they satisfied the

Job training

•

Education

work requirement (American Academy of Family

•

Volunteering

Physicians, 2020).

•

Caregiving

•

Community engagement activities

Challenges Implementing the Work Requirement

Policy. Research suggests that a work requirement

policy created the following hurdles for eligible beneficiaries (Hill and Burroughs, 2019; Wagner and Schubel, 2020):

3 CMS did not implement a work requirement policy; instead, it approved states’ requests to implement a work requirement policy.

4 Arkansas’ work requirements resulted in 18,000 Arkansans losing coverage and were halted by a judge in federal district court.

5 Work requirement policies were approved by CMS to be implemented in 12 states, including Arizona, Arkansas, Georgia, Indiana, Kentucky, Michigan, Nebraska, New Hampshire, Ohio, South Carolina, Utah, and Wisconsin.

6 For further information, see the article at https://www.kff.org/medicaid/issue-brief/an-overview-of-medicaid-work-

requirements-what-happened-under-the-trump-and-biden-administrations/.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Difficulty understanding the work requirement policy. Hill and Burroughs (2019) found that people interviewed generally had little knowledge and understanding of the policy, and many thought they were not subject to the policy. Understanding the policy was also more challenging for those with lower literacy and limited English proficiency, who are generally the target population of Medicaid.

Difficulty reporting work hours to stay in compliance. Participants are required to report work hours in an online system every month so they can stay in compliance. However, 33 percent of Medicaid-recipient adults had never used a computer before or had no access to the internet or a computer (Hill and Burroughs, 2019), which could lead to their mistakenly being disqualified from Medicaid benefits for noncompliance.

Lack of staff support. Lack of staff to assist beneficiaries by answering questions or providing reasonable accommodations for individuals with disabilities creates a bureaucratic maze that may lead to coverage loss for many eligible enrollees (Wagner and Schubel, 2020).

Impacts and Successes of the Work Requirement Policy. CMS noted that the work requirement policy can promote better health and improve well-being by increasing employment. However, several studies have shown that the work requirement policy was ineffective and potentially counterproductive (Garfield et al., 2018; Katch, 2016; Katch, Wagner, and Aron-Dine, 2018; Solomon, 2019; and Wagner and

Schubel, 2020).

The Medicaid work requirement policy led to large coverage losses. According to Aron-Dine, Chaudhry, and Broaddus (2018), the rigid work requirement policy led to 46 percent of low-income working adults covered by Medicaid facing risk of losing coverage because of failure to meet the 80-hours requirement every month. At the state level, the proportion of Medicaid beneficiaries losing insurance coverage due to the work requirement policy also appeared large, with 25 percent in Arkansas (Hardy, 2018), 33 percent in Michigan (Erb, 2020), and 40 percent in New Hampshire (Wagner and Schubel, 2020) . Coverage losses result in adverse consequences, including difficulty paying off medical debt, losing access to care, delaying care, worsened health conditions, and skipping medications because of the cost (Katch, Wagner, and Aron-Dine, 2018; Wagner and Schubel, 2020). For people with

disabilities, losing coverage is even more harmful because they often depend on regular care to manage their health (Wagner and Schubel, 2020).

The Medicaid work requirement policy failed to increase employment or reduce poverty. The work requirement policy in the Medicaid program failed to increase long-term employment or reduce poverty due to the following reasons (Garfield et al., 2018; Katch, Wagner, and Aron-Dine, 2018; Wagner and Schubel, 2020).

1. Most Medicaid enrollees were already employed. For example, Garfield et al. (2018) found that in Virginia, 51 percent of enrollees worked full time (at least 35 hours per week), and the

remaining 49 percent worked for only part of the year (26 weeks or more). However, many

beneficiaries were working low-paying jobs; 78 percent of Medicaid benefit recipients were paid hourly, and 36 percent earned an hourly wage at or below $10 an hour.

2. Sommers et al. (2019) and Sommers et al. (2020) found no evidence that the work requirement policy implemented in the Medicaid program promoted employment, increased the number of

work hours, or increased rates of community engagement activities. For example, the researchers found that in Kansas, the number of enrollees who met the requirement by reporting enough work hours every month was low.

3. Medicaid enrollees reported that they struggled with unstable work and faced barriers to

employment, such as a lack of access to transportation and childcare, low education, and lack of 11

A Review of Work Requirement Policies in HUD-Funded Assisted Housing

vocational training—barriers that, unfortunately, are not supported by Medicaid (Musumeci,

Rudowitz, and Lyons, 2018).

Summary

Research reveals that Medicaid’s work requirement policy does not promote better health, as evidence has consistently shown that the inclusion of a work requirement policy has led many people to lose or experience interruptions in Medicaid coverage. Moreover, the work requirement policy is ineffective in improving employment gains and moving people out of poverty. The following action was proposed to prevent more people from losing coverage.

 Pause Medicaid’s work requirement policy. The non-partisan Medicaid and Children’s Health Insurance Program Payment and Access Commission suggested pausing Medicaid’s work

requirement policy (Medicaid and CHIP Payment and Access Commission, 2018). Solomon

(2019) agreed that policymakers should follow this advice and pause the work requirement

policy.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Housing Assistance

Overview of Moving to Work’s Work Requirement

MTW Demonstration Program

Policy. Moving to Work (MTW) is a demonstration

program for public housing authorities (PHAs) that

The MTW demonstration program aims to help

has three objectives: (1) improving the cost

residents achieve self-sufficiency and improve housing

effectiveness of federal expenditures, (2) increasing

choices for low-income families. Between 1996 and

the self-sufficiency of assisted households, and (3)

2016, HUD designated 39 PHAs as MTW agencies. In

increasing housing choice (HUD, 2022b). As of

2016, Congress directed HUD to expand the MTW

program and add 100 PHAs to the program.

December 2015, 39 PHAs were designated as MTW

agencies, and those PHAs had the option of

Eligibility: Congress has authorized specific PHAs to

implementing a work requirement policy in either

become part of MTW, and, in others, Congress has

authorized HUD to competitively select the agencies

the Housing Choice Voucher (HCV) program7 or the

through its own processes.

public housing program. 8 To date, nine9 of those 39

initial agencies have ever implemented a work

Work Requirement Policy: The policy varies among

the nine initial MTW agencies, but they generally

requirement policy. The work requirement policies

require adult participants to be involved in work

that have been implemented vary by who is required

activities to receive assistance. Elderly households and

to participate, how work is defined, and how the

people with a disability are exempted from the work

requirements are enforced (Webb, Frescoln, and

requirements.

Rohe, 2015). All nine agencies implementing a work

Desired Outcome of the Policy: Varies across PHAs;

requirement policy require all work-able adults

in general, to help households achieve self-sufficiency

(between the ages of 18 and 54 or 61) to work at

and increase housing choices for participants.

least a certain number of hours (ranging from 15 to

Activities That Count Toward Work Requirement:

30) per week. For most agencies, participating in a

Varies across PHAs, but can include the following:

training or education program is also counted as

•

Full- or part-time employment

engagement in work activities (Hahn et al., 2017;

•

Job training

Levy, Edmonds, and Simington, 2018). In some

•

Full- or part-time enrollment in education

PHAs, the work requirement policy generally

•

Volunteering

applies to participants of all housing programs.

Other PHAs have slightly different policies for

different housing programs (for example, Lexington-Fayette Urban County Housing Authority [LHA]; LHA, 2020).

Sanctions for Noncompliance. Similarly, sanctions for noncompliance vary among the nine agencies. If households fall out of compliance with the work requirement policy, some agencies provide time for households to get back into compliance before terminating housing assistance altogether, whereas other agencies increase the household’s rent contribution (for example, increasing it to market rate). Most agencies give households a window of time, such as 14 days or even 90 days, to get back into compliance.

7 The HCV program is the federal government’s major program for assisting very low-income families, the elderly, and people with disabilities. A family that is issued a housing voucher is responsible for finding a suitable housing unit of the family’s choice where the owner agrees to rent under the program.

8 Public housing was established to provide decent and safe rental housing for eligible low-income families, the elderly, and people with disabilities. Public housing comes in all sizes and types, from scattered single-family houses to high-rise apartments for elderly families.

9 The nine agencies are the Housing Authority of the City of Atlanta, Housing Authority of Champaign County, INLIVIAN

(Charlotte, NC), Chicago Housing Authority, Delaware State Housing Authority, Lawrence-Douglas County Housing Authority, Lexington-Fayette Urban County Housing Authority, Louisville Metro Housing Authority, and Housing Authority of the County of San Bernardino.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Families frequently are assigned to work with a case manager to help them get back into compliance with the policy.

Assessment of the Work Requirement Policy. Five10 of the nine agencies assess their work requirement policies through partnering with universities, researchers, or consultants. They generally evaluated the effectiveness of the policies by measuring employment rates, household earned incomes, and TANF usage rates and determined unintended consequences by assessing eviction rates. The final assessment outcomes were included in their annual reports and sent to HUD for review. To date, rigorous research on public housing’s work requirement policy is scant; only one study (Rohe, Webb, and Frescoln, 2015) has conducted a relatively comprehensive evaluation on a work requirement policy, focused on the

INLIVIAN work requirement policy. That study examined only short-term effects during the year following implementation of the work requirement, an important limitation because some studies of work requirements in other programs have found that benefits faded over time and adverse effects grew.

The main findings of Rohe, Webb, and Frescoln (2015) are summarized and presented below.

 The study found that the proportion of residents paying minimum rent decreased (as compared with a comparison group) after the imposition of sanctions due to a work requirement policy. The study also found that case management alone did not reduce the percentage of residents paying minimum rent (which the study considers a proxy for earned income).

 In the absence of employment data from a comparison group, the study analyzed the end-of-

month data collected by case managers to track residents’ work efforts. The results show that the percentage of employed residents in INLIVIAN increased substantially following work

requirement enforcement, as residents did not want to be evicted for noncompliance. However,

the study found that among those working, the average number of working hours did not display an increase similar to the employment rate; it remained unchanged despite a number of additional households working, probably because the newly obtained jobs often were part time. Although

evidence exists of the effectiveness of work requirement policy in improving employment,

determining whether the increase in employment was sufficient to meaningfully pull residents out of poverty requires further investigation.

 The study found no evidence that the work requirement and sanction policies increased evictions, likely because of the INLIVIAN’s emphasis on assisting tenants to meet requirements instead of adopting a punitive approach. However, the study noted that one household was evicted due to

nonpayment of the increased rent (part of the sanction for noncompliance) in the year following the enforcement of the work requirement policy.

Findings of annual reports and other descriptive studies are summarized and presented below.

• The Housing Authority of Champaign County’s (HACC’s), Chicago Housing Authority’s

(CHA’s), and Lexington-Fayette Urban County Housing Authority’s (LHA’s) evaluations

suggested that the work requirement policies positively affected average household income

(HACC, 2019; Levy et al., 2019; LHA, 2020), consistent with the finding in Levy et al. (2019) that average annual household income per person subject to the work requirement had increased since CHA’s work requirement policy went into effect. However, Levy et al. (2019) argued that 10 The agencies assessing their work requirement policies in this manner are the Housing Authority of Champaign County (HACC), INLIVIAN (Charlotte, NC), Chicago Housing Authority (CHA), Lexington-Fayette Urban County Housing Authority (LHA), and Housing Authority of the County of San Bernardino (HACSB); the assessment discusses the entire PHA program and does not evaluate the work requirement policy specifically).

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

whether the marginal increase in income was attributable to the work requirement policy or the economic recovery from the Great Recession and the city’s increased minimum wage is unclear. 11

 The Delaware State Housing Authority (DSHA) reported that there were a growing number of

households positively moving out of assisted housing and purchasing their own homes in 2020

(Delaware State Housing Authority, 2020).

 LHA’s evaluation found that engagement in government assistance programs (for example,

TANF) decreased from 2017 to 2018 (LHA, 2018).

 Similar to Rohe, Webb, and Frescoln (2015), Levy et al. (2019) found no eviction due to the work requirement and sanction policies in CHA, likely because of the PHA’s emphasis of not adopting a punitive enforcement policy (which was also known to most residents). However, residents

interviewed in the study expressed their frustration with having CHA determine the number of

hours they should work; they suggested that working hours should vary on the basis of residents’

circumstances, such as the number of children in a household.

 HACC’s program assessment noted some major barriers to employment faced by households,

including having a large number of children, having a felony conviction on their record, and

having limited access to transportation and childcare (HACC, 2019). Levy et al. (2019) agreed that lack of childcare is one of the major barriers to employment in high-quality jobs encountered by residents participating in the CHA program. By examining the residents who failed to meet the work requirement of Housing Authority of the County of San Bernardino (HACSB), Distelberg

and Taylor (2010) identified similar barriers to employment, including health problems, lack of job skills, poor education, disability, and lack of transportation.

Summary

Although annual reports by agencies and one rigorous study (Rohe, Webb, and Frescoln, 2015) provide some insights regarding the impacts of implementing a work requirement policy in assisted housing, whether the increases in employment and household income associated with implementation of the work requirement policy reach a level that enables self-sufficiency remains unclear. In addition, because this limited research has focused on only five of the nine PHAs that have implemented a work requirement policy, little is known as to whether similar impacts reported by those agencies would be found in the remaining four agencies. Moving forward, Hahn et al. (2017) and Levy, Edmonds, and Simington (2018) noted that comprehensive examinations of the effectiveness of housing assistance work requirement policies across the nine agencies are critical for policymakers to gain a better understanding of the policy.

11 The city of Chicago raised its minimum wage from $8.25 to $11.00 in 2017 and subsequently to $13.00 in 2019.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

3. FINDINGS FROM KEY STAKEHOLDER INTERVIEWS

This section presents the findings from interviews with eight key stakeholders from industry groups, advocacy groups, and academics with expertise in the study of work requirements. Stakeholders included the following individuals:

1. Angela Rachidi—Senior Fellow and Rowe Scholar in Poverty Studies, American Enterprise Institute.

2. Deborah Thrope—Deputy Director, National Housing Law Project.

3. Diane Levy—Principal Research Associate, Metropolitan Housing and Communities Policy Center at Urban Institute.

4. Georgi Banna—Former Director of Policy and Program Development, National Association of Housing and Redevelopment Officials.

5. Michael Webb12—Managing Associate, Community Science.

6. Nicole Barrett—Moving to Work (MTW) Program Manager, MTW Collaborative.

7. Tim Kaiser13—Executive Director, Public Housing Authorities Directors Association (PHADA).

8. Will Fischer—Senior Director for Housing Policy and Research, Center for Budget and Policy Priorities.

The insights offered by those stakeholders can further our knowledge about the role of a work requirement policy in HUD-funded assisted housing, including considerations for policy design, implementation, and assessment of desired outcomes.

Designing a Work Requirement Policy for HUD-Funded Assisted Housing

The research team administered a semi-structured interview guide with each of the eight key stakeholders that was designed to gather information policymakers should consider when developing a work

requirement policy, including policy goals, target population, number of work hours, work-related activities, changes in rent structures, and entities that should be involved in the policymaking process. The stakeholders were selected on the basis of their knowledge and expertise on work requirement policies in assisted housing or other public assistance programs (for example, Temporary Assistance for Needy Families [TANF], the Supplemental Nutrition Assistance Program [SNAP], and Medicaid) and to ensure a diverse representation of perspectives. Stakeholders were informed that the study team was interested in their perspectives as experts, not necessarily the official position of their organizations. Some stakeholders noted that they were opposed to a work requirement policy in assisted housing, and their input reflected policy options that could, in their view, reduce the harm caused by a work requirement policy if one were implemented.

12 At the time of the interview, Dr. Webb was the Research Director at the Center for Urban and Regional Studies, University of North Carolina at Chapel Hill.

13 Mr. Kaiser requested the inclusion of two policy analysts affiliated with PHADA in his interview with the study team: Mr. Jim Armstrong and Mr. David Weber. The study classified the discussion as one interview despite having three interviewees.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Policy Goals. All stakeholders14 recommended that

if a work requirement policy were to be instituted,

I think that the goals would be that for people

policymakers should have the primary goal of

who are able to be employed, to support them in

increasing the employment and earned income of

their efforts to access gainful employment that

offers a living wage so that they’re not, in a way,

assisted households. Three stakeholders specified

financially burdened by it, which sounds

that employment should offer sustainable wages or,

somewhat counterintuitive, but it needs to be a

at least, wages that are enough to cover the costs

wage that would cover their costs. So if it’s

associated with being employed, such as childcare,

somebody who has not had to cover childcare

transportation, and clothing requirements (for

because they’ve been at home and now they have

example, steel-toed shoes and work uniforms). Four

to pay for childcare, what they earn from a job

would need to be able to cover that and [other

stakeholders stated that a work requirement policy

basic expenses] beyond that to help them on their

should help assisted households achieve self-

way financially.

sufficiency and allow them to permanently move out

of assisted housing. Two stakeholders suggested that

—Key Stakeholder

the additional goal should be to help assisted

households build assets.

Target Population. All stakeholders generally agreed that if a work requirement policy were implemented, the policy should exempt households that are not work-able, including elderly and disabled households. However, stakeholders’ views differed on how work-able, disabled, and elderly should be defined. Two stakeholders stated that public housing agencies (PHAs) should use HUD designations, whereas three stated that the decision should be left to individual PHAs. Two stakeholders stated that persons with caregiving responsibilities, such as parents of young children, should also be exempt from a work requirement policy.

Number of Work Hours. Stakeholders’ views varied with respect to the number of hours of work that should be required under the policy if a work requirement were implemented. Some stakeholders (n=3) stated that assisted households should be required to work full time (at least 30 hours per week), whereas others (n=2) noted that the requirement should be for part-time work (about 15 to 20 hours per week).

Two stakeholders suggested that PHAs could use a tiered system, in which work hours are increased over time. However, most stakeholders (n=6) agreed that flexibility should be used in determining the number of work hours, with considerations for local economies and job markets. Almost all (n=7) stakeholders stated that accommodations should be made for people with childcare needs.

Work-Related Activities. All stakeholders agreed that activities that help households find sustainable employment—such as job/career readiness activities, job/vocational training, apprenticeships, and internships—should count toward meeting any work requirement policy that would be established.

Stakeholders also agreed that participation in an educational program should count regardless of whether it is an adult education program, a certificate program, or a degree program. Two stakeholders recommended that volunteer or community service should also count in terms of meeting a work

requirement.

14 As detailed above, some stakeholders noted that they were opposed to a work requirement policy in assisted housing, particularly due to the punitive components of such policies. Those stakeholders were asked to participate in the discussion regarding work requirement as a thought experiment.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Changes in Rent Structures.. Stakeholders offered

various ideas on how to implement changes in rent

At the present time, if somebody’s earnings

increase, they do pay more rent. And a major beef

structures that could encourage work, such as the

that assisted households have is that rent

following:

calculations are based on gross income. So I walk

home with my check from Kroger’s. I work there

1. Disregarding a portion of the increased

as a checker, and I come home with my check

income for a period of time when

from Kroger’s, and they’ve taken out Social

calculating rent.

Security and income tax withholding, Medicare,

2. Implementing a tiered rent policy, in which

maybe some other state and local stuff, and my

households are grouped into tiers based on

rent goes up at 30 percent of the gross on that

check stub, not the net. And as a result, I end up

income. The rent is then fixed within each

with holding onto maybe 30 percent of what my

tier for a period of time (for example, 3

take-home is. And so the current rent policy, I

years) and stays the same during that period

think, is very punitive around earnings and does a

even if a household’s income increases.

lot of disincentive.

3. Saving a portion of the increased income in

—Key Stakeholder

an escrow account for assisted households

to use toward housing expenses, such as

homeownership or rent.

4. Recertifying compliance with the work requirement on a biannual or triennial basis—or even more frequently—instead of annually.

Several stakeholders (n=5) also recommended that policymakers should look at examples of MTW PHAs that have implemented rent reforms effectively.

Entities That Should be Involved in the Policymaking Process. Stakeholders recommended that the following entities should be involved in the policymaking process:15

1. Assisted households, whether directly or through advocacy organizations.

2. PHA staff who will be involved in the implementation of the policy.

3. Service providers and community organizations that will be involved in the provision of

supportive services.

Some stakeholders (n=2) stated that property managers or owners and industry groups should also be involved in the process, whereas others (n=5) recommended that HUD’s role in the policymaking process should be to set policy guidelines, serve as a resource for information, and provide oversight. Certain stakeholders (n=2) noted that HUD could also play an instrumental role in facilitating collaboration and coordination of services among government agencies at the federal, state, and local levels because assisted households often are involved with other public assistance programs, such as TANF, Medicaid, and SNAP.

15 Stakeholders did not specify whether those entities should be engaged in policymaking at the PHA level, federal level, or both.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Policy Framing. Several stakeholders (n=4)

expressed concern with the framing of the policy as

I want to just also know if there’s a way to move

from the work requirement language because I

a “work requirement” because the term has negative

think if you’re providing job training

connotations and is politically divisive. They noted

opportunities, vocational training, or work

that the term does not accurately reflect the work-

opportunities and it’s nonpunitive, I think moving

related activities and support services often included

away from the work requirement language is

as part of the policy. Stakeholders recommended

really important because people hear “work

requirement” and totally freak out.

changing the name of the policy to, for example,

Understandably.

“economic self-sufficiency policy” or “work

incentive policy.”

—Key Stakeholder

Implementation and Monitoring of a Work Requirement Policy for HUD-

Funded Assisted Housing

The second set of interview questions focused on what policymakers should consider pertaining to implementation of a work requirement policy and monitoring of compliance with the policy.

Implementation of Work Requirement Policy

Phase-In Period. Most stakeholders (n=6) agreed that households should be given an adequate phase-in period (that is, a notice period) before a work requirement policy becomes effective. Stakeholders’ views on what constitutes an adequate phase-in period varied widely, with stakeholders recommending 6-, 12-, 18-, or 24-month phase-in periods. Almost all (n=7) stakeholders recommended that the appropriate length of time for the phase-in period should be left to individual PHAs and be based on factors such as the local job market and economy, availability of support services, and activities that count toward meeting the work requirement.

Effective Communication. All stakeholders suggested that effective communication of a work requirement policy requires language access (for non-English speakers) and the use of multiple platforms, including one-on-one meetings; in-person and virtual community meetings; electronic communications (for example, emails and e-newsletters); flyers or bulletins; and mailers, among others. Specifically, several stakeholders (n=4) recommended that PHAs should communicate information about a work

requirement through public-facing staff (for example, case managers, property managers, and service providers) who interact with assisted households on a day-to-day basis and often have established relationships with them. Some stakeholders (n=3) recommended that PHAs can also communicate with assisted households through resident leaders or resident councils, especially for housing choice voucher (HCV) households.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Concerns or Needs that Should Be Considered.

Most stakeholders (n=7) agreed that barriers that

For a work requirement policy in the housing

assistance programs to work, there does need to

prevent assisted households from participating in the

be services provided. And that includes around

labor market should be considered if designing a work

employment, so job search help, help with soft

requirement policy. In particular, stakeholders cited

skills in terms of how just even to interview, how

barriers such as lack of access to childcare, lack of

to show up to work on time, as well as hard skills

reliable transportation, lower educational attainment,

for people that don’t have hard skills or [skills

that are] marketable in the labor market. But then

language barriers, substance abuse, mental health,

it goes even beyond that in terms of other social

domestic violence, and child welfare involvement.

services. So if there is domestic violence in the

Some stakeholders (n=4) stated that policymakers

household, or if there is a child welfare

should also consider local socioeconomic conditions,

involvement, or if there’s past history of

such as job market, economy, skills mismatch, and

homelessness or any sort of trauma in the

household, those also can prevent people from

concentration of poverty.

entering the labor market.

Supportive Services. All stakeholders mentioned that

—Key Stakeholder

comprehensive supportive services would be crucial

to the implementation a work requirement policy in

assisted housing. They stated that supportive services should be targeted to address the barriers and needs of assisted households in a holistic manner related to childcare, transportation, job search, job readiness, job training, educational programs, financial literacy, afterschool programs, case management, mental health services, and substance abuse treatment, among others. Many supportive services are beyond the scope and capabilities of PHAs, and stakeholders acknowledged that those agencies must establish partnerships with community partners, such as Workforce Investment Boards, community colleges and universities, trade groups (for example, chambers of commerce), employers, childcare providers, financial literacy organizations, youth organizations, social service providers, and healthcare providers. Several stakeholders (n=5) also suggested that HUD can support PHAs in the provision of those supportive services by providing funding or facilitating coordination of service delivery with other government agencies, such as the U.S. Department of Labor and the U.S. Department of Health and Human Services.

Benefits Reduction Resulting from Increases in Earned Income. All stakeholders agreed that a challenge to increasing earned income among assisted households is the resulting possible reduction in benefit eligibility in other programs (for some tenants those reductions are fully or partially offset by increases in benefits, such as the Earned Income Tax Credit.) Stakeholders noted that no easy solution to the problem exists because HUD and PHAs do not have control over the policies of other public benefit programs such as TANF, Medicaid, and SNAP. Some stakeholders offered the following potential

solutions: (1) disregarding increased income for a period of time and (2) interagency coordination of public assistance programs such as housing assistance, TANF, Medicaid, and SNAP.

Monitoring of a Work Requirement Policy

Compliance Monitoring. Stakeholders offered various suggestions on how PHAs could monitor assisted households’ compliance with a work requirement policy:

1. Using a tracking system in which PHA staff or employment service providers can verify

employment information and enter it in the tracking system.

2. Verifying compliance during recertification, whether annually, biannually, or triennially.

However, assisted households should be required to report any loss of job or change in income within a specified period.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

3. Allowing assisted households to self-report employment status as much as possible. PHA staff would then verify the information as needed.

4. Working directly with employers.

Sanctions for Noncompliance. Most stakeholders

(n=6) agreed that households who are not in

The most popular way has been kind of

increasing rent sanctions. Again, there’s an

compliance with a work requirement policy should

administrative burden attached to that. But I

be given multiple opportunities to come into

think from a program standpoint, it probably

compliance before sanctions are imposed.

makes more sense. If your goal is to increase self-

Stakeholders recommended that PHAs should work

sufficiency and to get residents working. I mean,

with assisted households to address any barriers to

certainly increasing rent sanctions is a more

effective way.

employment. Most stakeholders (n=6) stated that

assisted households should not be sanctioned for

—Key Stakeholder

factors beyond their control—for example, lack of

job opportunities due to an economic downturn. Several stakeholders (n=4) also recommended a soft sanctions approach, in which assisted households are given warnings, which can be escalated to sanctions such as an increase in rent. Most stakeholders (n=5) agreed that eviction or termination from an assisted housing program should be a sanction of last resort and should be used on very rare occasions. Some stakeholders (n=2) shared the perspective that eviction or termination should never be used as a sanction for noncompliance with a work requirement in assisted housing.

Suspension of Policy. Most stakeholders (n=7) agreed that a work requirement policy should be suspended during periods of economic downturn; natural disasters (for example, severe storms and tornados); and public health emergencies (for example, the COVID-19 pandemic). Four of the seven PHAs have suspended their work requirement policy due to the COVID-19 pandemic, and the remaining three have made necessary changes to their day-to-day operations in response to the pandemic (see additional details in the Case Studies Synthesis and Key Findings chapter).

Desired Outcomes of a Work Requirement Policy in HUD-Funded Assisted Housing

The third set of questions focused on what measures policymakers might assess when evaluating the effectiveness of a work requirement policy.

Policy Assessment. All stakeholders emphasized the importance of evaluating a work requirement policy to measure the positive outcomes of the policy, including increases in employment or earned income, and less desirable outcomes, such as increased hardship for households subject to the policy. Stakeholders highlighted several outcome measures that should be tracked:

 Rates of employment.

 Earnings.

 Number of hours worked.

 Job tenure—that is, length of time with a particular job.

 Employment tenure—that is, length of time in the workforce.

 Tenure in assisted housing.

 Number of assisted households sanctioned (including types of sanctions).

 Number of assisted households exiting the program (including reasons for exit).

 Destinations of assisted households who exit the program (short-term and long-term).

 Number of households achieving self-sufficiency.

 Number of households participating in workforce development activities and programs.

 Rent payment.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

 Number of households receiving supportive services.

 Assets.

 Rates of poverty.

Most stakeholders (n=7) recommended that outcomes be tracked over long periods of time, at least 5

years, especially for assisted households who exit assisted housing after achieving self-sufficiency or as a result of sanctions. In addition, several stakeholders (n=3) recommended that assisted households be surveyed to learn more about their experiences.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

4. CASE STUDIES SYNTHESIS AND KEY FINDINGS

This section synthesizes findings from the case studies of the nine Moving to Work (MTW) agencies that have ever implemented a work requirement policy. First is an overview of the public housing agencies (PHAs) and the characteristics of their work requirement policies, then comes discussion of the development and implementation of the work requirement policies at each PHA. Appendix B describes case studies providing in-depth information about each of the nine PHAs and the details of their individual work requirement policies.

Overview of Nine PHAs and Their Work Requirement Policies

The nine MTW agencies that have ever implemented a work requirement policy are diverse in size, maturity of implementation of work requirement policies, and key program parameters and requirements.

(See exhibit 2 for an overview of key work requirement characteristics by PHA). Among the nine PHAs, the Delaware State Housing Authority (DSHA) and Lawrence-Douglas County Housing Authority

(LDCHA) have been implementing their work requirement policies for the longest time (since 1999), followed by Atlanta Housing (AH) and Chicago Housing Authority (CHA), which instituted a work requirement policy in Fiscal Years (FYs) 2005 and 2009, respectively. The Housing Authority of Champaign County (HACC), INLIVIAN (formerly Charlotte Housing Authority), and Lexington-Fayette Urban County Housing Authority (LHA) were the most recent PHAs to implement a work requirement policy, in 2013 and 2014. Two PHAs have sunset their policies: Louisville Metro Housing Authority (LMHA) implementation started in 2007 and ended in 2017, and the Housing Authority of the County of San Bernardino (HACSB) work requirement policy for inbound housing choice voucher (HCV)

portability households was implemented from 2010 to 2019 and for the Maplewood Homes Public

Housing Community from 2013 to 2016.

Number of Households Affected. The annual

Some PHAs apply work requirements to both

number of households associated with work

public housing and HCV residents.

requirement policies varied greatly, with 106‒420

households in smaller programs (for example, LMHA) and 5,900‒8,000 households in larger programs (for example, AH and CHA).

Age Requirement. All PHAs specified the ages of

Elderly and household members with a disability

assisted households subject to work requirements,

are exempted from work requirements at all nine

but those ages varied. Generally, work-able adults16

PHAs.

ages 18 years and older were required to engage in

employment, but two PHAs extended the requirement to minors: AH required youths ages 16 and 17

years to work unless they were enrolled in school; CHA required 17-year-olds in assisted households who were not attending school to be employed. The age requirements for older adults varied as well: six PHAs set the upper age limit at 61 years, two PHAs at 54 years, and one PHA at 57 years. All PHAs except LHA and INLIVIAN required all eligible work-able individuals to be compliant with the work

requirement. LHA required only the heads or co-heads/spouses of eligible households to be compliant, and INLIVIAN required only one work-able individual in eligible households to be compliant.

16 The definition of work-able adults varied between PHAs but generally excluded adults who were elderly or had a disability.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Exhibit 2. Key Characteristics of the Work Requirement Policy by PHA

Policy

Approximate Number of

PHA

Implementation Start Assisted Households Affected Household Members Subject to

Employment or Self-Employment

Date

Annually

Work Requirement

Hour Requirements17

All work-able individuals ages 18–

AH

FY 2005

8,600; public housing and HCV

(PBV).

61 years; youths ages 16 and 17

Average 20+ hours/week.

years not enrolled in school.

All work-able individuals ages 18–

CHA

2009

5,900; public housing and RAD

20+ hours/week of work or work-

conversion units.

54 years and 17-year-olds who are

not attending school.

related activities.

Years 1 and 2: 20+ hours/week.

DSHA

1999

420; public housing and HCV.

All work-able individuals ages 18–

57 years.

Year 3: 25+ hours/week.

Years 4 through 7: 30+ hours/week.

HACC

2013

1,200; HCV (including PBV).

All work-able individuals ages 18–

25+ hours/week.

54 years.

2010–2019 for

inbound HCV

179 individuals (in 2013) at one

public housing site (Maplewood

In Phases I and II: work-related

HACSB

portability; 2013–2016

All work-able individuals ages 18–

activities (but limited to 4 years).

for one public housing Homes Community); number of 61 years.

In Phase III:15+ hours/week of

site (Maplewood

inbound HCV portability

employment.

Homes Community)

households is unknown.

INLIVIAN

2014

3,600; HCV (including PBV).

At least one work-able individual

20+ hours/week across eligible

ages 18–61 years in a household.

members of the household.

15+ hours/week for each work-able

adult.

LDCHA

1999

400; public housing and HCV.

All work-able individuals ages 18–

61 years.

35+ hours/week for two-adult

households with a child age 13 years

or younger. 18

2014 for newer public 813; newer public housing units,

In LSS I: 37.5+ hours/week.

LHA

housing units and one

Work-able heads-of-household or

PBV site; 2018 for 18

one PBV site, and 18 HCV

co-heads/spouses ages 18–61 years. In LSS II and Centre Meadows [PBV

HCV households

households.

site]: 20+ hours/week.

LMHA

FY 2007–FY 2017

106 (in 2016); new single-

All work-able individuals ages 18–

family public housing units

61 years.

20+ hours/week.

17 The number of hours is per individual except for INLIVIAN, where the number of hours is per household.

18 Only one work-able adult is required to meet the 35+ hours/week work requirement for this type of household.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

AH = Atlanta Housing. CHA = Chicago Housing Authority. DSHA = Delaware State Housing Authority. HACC = Housing Authority of Champaign County. HACSB = Housing Authority of the County of San Bernardino. HCV = housing choice voucher. LDCHA = Lawrence-Douglas County Housing Authority. LHA = Lexington-Fayette Urban County Housing Authority. LMHA = Louisville Metro Housing Authority. LSS = Local Self-Sufficiency. PBV = project-based voucher.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Hours and Work Requirement. The number of required work (or work-related) hours per week and the type of activities that fulfill the work requirement also varied across the nine PHAs. See exhibit 2 for further details on the hours and work requirement for each PHA.

DSHA increases the required work hours for residents as they progress: 20+ hours/week in

years 1 and 2, 25+ hours/week in year 3, and 30+ hours/week in years 4 through 7. In years 1 through 3, residents can pursue part-time education or job training to fulfill the work requirement, but starting in year 4, only paid employment can fulfill the work requirement.

INLIVIAN planned to increase the required work hours across the two phases of the

program: 15+ hours/week in phase 1 and 30+ hours/week in phase 2; however, that plan

was not implemented, so specific details are not available. In year 1 (the start of an

individual’s eligibility), engagement in education, job training, or volunteering counted toward the work requirement, but starting in year 4, only paid employment fulfilled the work requirement. However, the PHA found monitoring this tiered work requirement to be overly

complicated and ultimately modified the work requirement to mandate a minimum of 20

hours of employment per week, per household to simplify compliance monitoring.

Term Limits. Four PHAs paired their work requirement policy with term limits on the receipt of housing assistance. HACC implemented an 8-year term limit on assistance, DSHA implemented a 7-year term limit, LMHA implemented a 5-year term limit, and LHA implemented a 5-year term limit with the potential for a 2-year extension. LHA’s term limit applied to only 18 households in the HCV Time Limit Pilot Program.

Other PHAs enforced a phased approach in which each phase had a limited length. For example, public housing assisted households in HACSB were allowed a maximum of 2 years in phase I and an additional 2 years in phase II. For an overview of qualified types of activities, see exhibit 3.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Exhibit 3. Activities That Qualify Toward the Work Requirement

Qualified Activity

Public Housing Authority

AH

CHA

DSHA HACC HACSB INLIVIAN LDCHA LHA LMHA

Paid Employment



















Self-Employment







Volunteeringa









Education/Job Trainingb

Full-time enrollment



















Part-time enrollment 









AH = Atlanta Housing. CHA = Chicago Housing Authority. DSHA = Delaware State Housing Authority. HACC = Housing Authority of Champaign County. HACSB = Housing Authority of the County of San Bernardino. LDCHA = Lawrence-Douglas County Housing Authority. LHA = Lexington-Fayette Urban County Housing Authority. LMHA =

Louisville Metro Housing Authority.

a CHA: 10 of 20+ required work hours may be achieved through volunteering; INLIVIAN: 8 to 15 hours/week and volunteering are allowed for up to 60 days during households’ tenure in assisted housing; LDCHA: 15+ work hours may be achieved through volunteering; HACSB: In phases I and II of the program, volunteering may fulfill the work requirement.

b AH and CHA: A combination of part-time education or training and part-time paid employment may fulfill the work hour requirement; DSHA: For the first 3

years, full-time enrollment in an educational or training program may fulfill the work requirement, as well as a combination of part-time education or training and part-time employment; HACSB: In phases I and II, vocational training, GED classes, apprenticeship, and enrollment in an educational program may all fulfill the work requirement; INLIVIAN: GED preparation or work toward a 2- or 4-year degree must be combined with part-time employment (15+

hours/week), and job training is allowed for only up to 12 months during households’ tenure in assisted housing; LHA: only paid on-the-job training qualifies.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Evaluation Efforts of the PHAs. All nine PHAs

internally track and monitor key program metrics,

INLIVIAN is the only agency that conducted a

third-party outcome evaluation of its work

such as such as year-over-year earnings and

requirement policy, focusing on employment and

employment engagement of assisted households.

evictions.

Some PHAs had engaged in an initial assessment of

household employment barriers and supportive service needs before the implementation of their work requirement policies. Those assessments led to PHAs providing wraparound services for families who were subjected to the work requirement policy. At various points in their policy development and implementation, some agencies have engaged with local research centers and university-based consultants to assess their program outcomes.

Initial Assessments:

 AH contracted with an urban planning research firm to conduct an independent study of its efforts to deconcentrate poverty in assisted household communities. The study’s findings helped inform the development of the PHA’s MTW program, including the work requirement policy.

 CHA worked with a local research center to conduct focus groups with various stakeholders, generating valuable information about early implementation challenges of its work requirement policy.

Annual Assessments:

 HACC involved a consultant in its policy development and has partnered with a university to help with the agency’s annual reports.

 LHA engages a university-based consultant to conduct an annual assessment of the agency’s

MTW initiatives.

 HACSB contracted a university to conduct a needs assessment study of the Maplewood Homes

Public Housing Community that compared the needs of residents at the site between 2010 and

2016.

Development of a Work Requirement Policy

Motivations and Goals. The PHAs shared

overarching goals for implementing a work

So I think, overarchingly, we want to see our

families thrive. Back when we got the Moving to

requirement policy: promoting economic self-

Work designation, we knew that we wanted to get

sufficiency and assisted households’ quality of life.

our families out of that concentrated poverty

PHAs reported that, combined with supportive

environment because we knew it didn’t have any

services, the work requirement policy encourages

good outcomes for our families and the cycle, the

assisted households to gain or retain jobs.

generational cycle of living in poverty. So a lot of

our work under MTW has been deconcentration

Additional goals reported by the PHAs were

of poverty.

reducing cost and achieving greater cost-

—AH Staff Member

effectiveness in federal expenditures. Two agencies

(CHA and AH) implemented work requirement

policies as part of their broader plans and public housing portfolios. To help households move away from communities with concentrated poverty, the two PHAs redeveloped their public housing into mixed-income housing.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Policy Development Considerations and Stakeholders Involved. In developing their work requirement policies, PHAs considered the barriers that assisted households often face in achieving self-sufficiency and exiting housing assistance. Barriers identified by assisted households included—

 Lack of affordable housing.

 Transportation.

 Childcare.

 Limited local employment opportunities.

 Poor credit history.

 Lack of skills and education.

 Generational poverty.

 Low-performing schools.

Most PHAs involved their leadership and local partner organizations in the development of the work requirement policy. Those agencies reported that their resident services or resident advisory councils, local housing advocacy groups, and homeless services networks were involved in the development of the policy. As previously mentioned, three PHAs also engaged outside consultants in their policy

development work.

Policy Changes. Over the years, PHAs have

One-half of the PHAs have reduced the required

modified their work requirement policies in several

number of hours of work, and two PHAs have

ways to adjust to local job market conditions,

dropped their work requirement completely.

increase the number of households eligible to

participate in their work requirement policies, and facilitate assisted households’ compliance with the work requirement policy.

Four PHAs modified their work requirement by decreasing the required number of work or work-

related hours.

 In FY 2007, LDCHA reduced the number of required work hours per week from 20 to 15 because an economic downturn made finding and retaining jobs difficult for assisted households.

 AH reduced required work hours from 30 to 20 hours per week 10 years into implementing the policy. The key rationale prompting the change was that AH realized that most of its assisted households were being “penalized” for working in jobs where employers would not schedule

their employees for 30 or more hours to avoid triggering the requirement to provide insurance under the Affordable Care Act (ACA). 19

 In FY 2010, LMHA reduced its required work hours from 30 to 20 hours per week because its

assisted households were affected by the downturn in the local economy.

 INLIVIAN’s work requirement policy was a phased model, which initially conceived that

assisted households would progress from 20 to 30 hours of required work per week. The policy

also specified required hours for the head of household and other household members. Due to a significant administrative burden to track compliance with required work hours and to help

families graduate from minimum rent, the policy was modified to institute a 20-hours/week work requirement across all members of a household for assisted households in both phases of the

program.

19 ACA, sometime called Obamacare, is a federal healthcare statute that Congress enacted and signed into law in 2010. For more information about ACA, see: https://www.healthcare.gov/where-can-i-read-the-affordable-care-act/.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

By contrast, two PHAs increased the number of required work hours.

 DSHA increased its required work hours from 20 to 25 hours per week for assisted households in year 3, and from 25 to 30 hours per week for assisted households in program years 4 through 7.

The PHA reported that MTW participants often achieved the 20-hours-per-week work

requirement but did not increase their hours beyond that requirement, prompting a revision of the policy.

 HACC also increased its required work hours from 20 to 25 hours per week during its second year of policy implementation.

Other policy changes included extending time for assisted households to become compliant with work requirements before imposing sanctions.

 CHA increased the time for each Safe Harbor period—that is, a period when assisted households can obtain an exemption from the work requirement policy—from 90 to 180 days to provide

assisted households adequate time to work with service providers on becoming compliant with

the work requirement policy.

Policy Changes Resulting from the COVID-19

Pandemic. Due to the COVID-19 pandemic, four of

We haven’t technically suspended it, even with

the pandemic. We knew that it affected our

the seven PHAs with a work requirement policy

residents, but because we have Safe Harbor we

(AH, DSHA, INLIVIAN, and LDCHA) suspended

certainly knew that there might be periods of time

their policy. Specifically, INLIVIAN waived

where people would go to that. I think we are a

enforcement of the work requirement policy and

bit more liberal in acknowledging that people

increased its capacity to provide coordinated case

were losing their jobs or their jobs were unsafe to

go to because a lot of times we’re talking about

management services and oversee the assisted

the frontline worker that was essential and low

households’ health.

paid.

Three PHAs (CHA, HACC, and LHA) did not

—CHA Staff Member

suspend their work requirement policies but made

necessary changes to their day-to-day operations in response to the pandemic. For example, HACC

continued to accept vital documents from assisted households through email, fax, or drop box and launched virtual online briefings beginning in April 2020. CHA reported that, due to job losses and health and safety reasons, the agency expected more assisted households to enter Safe Harbor status, which allows assisted households a 180-day exemption from the work requirement policy. LHA waived the requirement for the 3 months work history to be consecutive; it also waived imputed rent for public housing households.

Implementation of a Work Requirement Policy

Supportive Services. The MTW agencies implementing work requirements provide a wide range of supportive services directly or through community organizations to promote assisted households’

employment and educational attainment and to help them address barriers to employment. For an overview of the types of supportive services offered by the PHAs, see exhibit 4. Case management and employment services are specifically highlighted below. Most of the PHAs offer case management, employment or workforce development services, or both to their assisted households. However, the types of services vary and are provided in different ways. For example—

 AH and CHA contract with various service providers to provide a wide range of workforce

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

development services, including job readiness and training, career counseling, job coaching and retention support, and employment referrals, among others.

 LDCHA employs two Employment Specialists who help assisted households become ready for work by engaging them in activities such as resume and cover letter preparation, conducting

mock interviews, and helping them purchase an interview outfit. The PHA’s community partners

(for example, Lawrence Workforce Center, Peaslee Tech, and Kansas University) provide job

training, and the PHA has a computer lab where assisted households can conduct job searches.

 HACSB contracted with the local workforce development department to visit the public housing residents once a week to provide onsite services such as job search and placement, resume

writing, career assessment and counseling, interviewing techniques, and training or job referrals.

 DSHA case managers work with assisted households to identify employment and training needs and then refer the households for services at the Delaware Department of Labor One-Stop

Centers. At the One-Stop Centers, assisted households can receive services such as resume

preparation, job searching, interviewing skills, and job training. Assisted households also have access to the PHA’s computer labs to conduct job searches.

 INLIVIAN works with local community partners (e.g., Charlotte Works [local workforce

development board] and other local partner organizations) to offer assisted households a range of workforce development services, including job readiness, career assessment, job search and

placement, and job training.

 HACC provides a pre-apprenticeship program through YouthBuild for households where youths

are subject to a work requirement. The PHA’s development partners and contractors provide

assisted households with construction job training and placement. Assisted households also

receive referrals for job readiness assistance.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Exhibit 4. Types of Supportive Services Provided by PHAs or their Community Partners

Public Housing Agency

AH

CHA

DSHA

HACC

HACSB

INLIVIAN

LDCHA

LHA

LMHA

Case Management

Mandatory

Mandatory; has Mandatory only Optional.

Optional;

Initially

only if a

onsite case

if a household

provided on site

mandatory,

household falls managers.

falls out of

in properties.

then made

out of

compliance.

optional.

compliance.

Employment/Workforce Development Services

Job readiness,

Job readiness, Range of

YouthBuild/

Contracted Job readiness

Job readiness,

Referrals to Referrals to

training, job

training, job

services

Apprenticeship with a local and placement,

training, job

local

local

search and

search and

through the

Program,

workforce

range of

search and

employers

employers

placement,

placement,

Delaware

training in

developme

employment

placements, job

and

and local

career

career

Department of

construction

nt

services through training through

employmen workforce

counseling, job counseling,

Labor One-Stop jobs through

department local

local One-Stop

t services

investment

coaching and

job coaching,

Centers.

contractors and for onsite

partnerships,

Center, and

providers.

board.

retention

referrals,

development

employmen including local

employment

support,

among others.

partners, job

t services

workforce

referrals.

referrals,

search and

(once a

development

among others.

referrals.

week).

board.

Education Services

Adult basic

Adult basic

Adult basic

Academic

Adult

College prep and Adult basic

education, GED education,

education, GED counseling,

literacy.

readiness

education, GED

classes.

GED classes.

classes.

scholarships

programs,

classes,

and grants,

college

assistance with

tutoring.

scholarships.

school enrollment

and financial aid

applications,

tutoring.

Childcare/Afterschool programs

Afterschool and Afterschool

Onsite day care Referrals for

Referrals

Childcare

Onsite day care

Referrals

summer

programs,

centers,

childcare.

for

subsidies,

center, childcare for

programs,

summer youth afterschool

childcare.

afterschool

assistance, early childcare

childcare

employment

programs,

programs,

childhood

assistance

assistance.

program,

summer youth

summer

education, baby

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Public Housing Agency

AH

CHA

DSHA

HACC

HACSB

INLIVIAN

LDCHA

LHA

LMHA

childcare

development

activities, early

supplies,

and

assistance,

initiatives,

education

parenting

services.

early childhood parenting

program.

education,

education,

classes.

afterschool

parenting

program.

resources.

Homeownership/Economic Mobility Programs

Down Payment Homeowners

Homeownership SHIFT, an FSS

Financial

Homeownership Homeownership

Assistance

hip education education and

program that

literacy.

program.

program,

Program,

and

counseling,

helps HCV

financial literacy.

homeownership counseling,

financial literacy, heads of

education and

economic

MTW Savings

household

counseling,

stability

Account, an

achieve

Good Neighbor education,

escrow account.

economic self-

Program,

financial

sufficiency,

financial

literacy.

including

literacy.

homeownership. Other Services

Aging well

Family

Self-

Transportation

Grants for car

Referrals

programs,

coaching,

sufficiency services, youth

repairs, bus

for social

assistance with

clinical

coaching

sports, and

passes, funding

services.

basic needs

services and

and

athletics

for driver’s

such as

referrals,

referrals,

programs.

education,

transportation,

assistance with

social

nutrition,

clothing,

basic needs

services

assistance with

utilities, health

such as

referrals.

clothing for

care, among

transportation,

work.

others.

clothing,

health care,

among others.

AH = Atlanta Housing. CHA = Chicago Housing Authority. DSHA = Delaware State Housing Authority. FSS = Family Self-Sufficiency. GED = General Educational Development. HACC = Housing Authority of Champaign County. HACSB = Housing Authority of the County of San Bernardino. HCV = housing choice voucher. LDCHA =

Lawrence-Douglas County Housing Authority. LHA = Lexington-Fayette Urban County Housing Authority. LMHA = Louisville Metro Housing Authority. MTW = Moving to Work.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Compliance Monitoring. At some PHAs, compliance monitoring is done by agency staff; others engage property managers and service providers. Other aspects of compliance monitoring vary across the PHAs as well, such as the frequency and process for rent recertification and the implementation of sanctions for noncompliance. At all PHAs, staff help noncompliant households directly or refer them for needed services to help them return to compliance.

At CHA, service providers and property managers monitor compliance, whereas CHA’s

Departments of Resident Services and Property & Asset Management document and track

data collected from assisted households. Data tracked include the reason for requesting a Safe Harbor exemption and the timeframe for tracking the 180 days. CHA then pulls the

data every 180 days to determine assisted households’ compliance with the work

requirement. Noncompliant households can request Safe Harbor exemption but must

participate in mandatory support services if approved. The 180-day exemption can be

reapproved an unlimited number of times with the service provider’s approval.

DSHA requires households to present their pay stubs to a case manager on a quarterly basis.

In the event of a job loss, households are given 30 days to find a new job; otherwise, they receive a compliance violation warning. After three such warnings, households can lose

housing assistance. The PHA also has sanction waivers, allowing exemptions from work

requirements due to medical emergencies and other extenuating circumstances.

For an overview of compliance monitoring processes and sanctions for noncompliance at the nine PHAs, see exhibit 5.

Challenges. PHA staff mentioned the following key challenges in implementing a work requirement policy:

 Early implementation challenges, such as securing staff buy-in for the policy and achieving resident awareness and understanding of the work requirement policy.

 Assisted households’ concerns that being employed will cause them to experience a “benefits cliff,” making them no longer qualified for other types of public assistance they depend upon.

 A lot of time spent on compliance monitoring and tracking, leaving PHA staff with limited time to provide supportive services.

 Motivating assisted households who experience multiple barriers to engage in work and providing support to address the barriers that are identified.

 Stigma associated with receiving housing assistance that makes finding employment difficult for assisted households.

 Local job market conditions and low minimum wage that make achieving self-sufficiency

difficult for assisted households.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Exhibit 5. Compliance Monitoring Process and Sanctions for Noncompliance by PHA

Compliance Monitoring Process

Sanctions for Noncompliance

Recertification is on an annual, biennial, and

In the event of a job loss, households are referred to employment services and given 90

triennial basis depending on the household’s

days to find a new job.

AH

compliance status.

Rent relief is granted on a case-by-case basis.

Conducted by PHA for households in the HCV

Noncompliant households can be terminated, but it is a rare occurrence. Staff reported that

program and by property managers in the public

over the past 8 years, AH has terminated only 64 households from the program for failure to

housing program.

comply with the work requirement, including nonparticipation in referral service activities.

In the event of a job loss, households can enter Safe Harbor status.

Monitoring is done by service providers and

Households can have 180-day exemptions approved for having a child younger than age

CHA

property managers; CHA’s Departments of Resident 1 or for experiencing domestic violence.

Services and Property & Asset Management ensure Noncompliant households are subject to lease termination and eviction. However, staff that data are being tracked correctly.

reported that CHA has never evicted any household for noncompliance with the work

requirement since the policy went into effect in 2009.

In the event of a job loss, households are given 30 days to find a new job.

After three compliance violation warnings, households can lose housing assistance,

DSHA

Households must present their pay stubs to a case

although it is a rare occurrence. Staff reported that the policy has been in place since

manager on a quarterly basis.

1999, but less than 2 percent of households have ever received a third strike.

DSHA has sanction waivers, allowing exemptions from work requirements due to

medical emergencies and other extenuating circumstances.

Compliance monitoring is done by PHA staff at the In the event of a job loss, households have 90 days to either find a job or enroll in an education program to get in compliance.

HACC

household’s annual recertification.

Households are required to present proof of

Noncompliant households can be terminated from the program.

employment, such as pay stubs.

HACC has sanction waivers, allowing exemptions from work requirements due to

medical or sole caregiver reasons.

Recertification was annual and done by an onsite

When not in compliance, households were given 90 days to become compliant and were

HACSB

coach for the Maplewood Homes Public Housing

able to extend it for an additional 90 days; for public housing, sanctions included rent

Community and by an HACSB Housing Services

being increased to market rate; for HCV households, previous imputed income

Specialist for inbound HCV portability households. determined rent subsidy.

Monitoring is done by life coaches in coordination

In the event of a job loss, households get a 90-day window to comply before rent

with property managers.

sanctions begin.

INLIVIAN Life coaches meet with the property managers on a

After 90 days in noncompliance status, Phase I sanctions are imposed: the household’s

monthly basis to review and discuss households’

income is calculated using the state minimum wage multiplied by the number of hours in

compliance with the work requirement.

the work requirement (i.e., 20 hours/week) for up to 3 months, then sanctions are

escalated to Phase II.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Compliance Monitoring Process

Sanctions for Noncompliance

Under Phase II Sanctions, households lose 100 percent of their housing subsidy for up to

180 days and are required to pay the established contract rent. If the household remains

noncompliant after that period, it is recommended for termination and receives an

informal hearing before final program termination. However, terminations from the

program due to noncompliance with the work requirement are very rare. Staff reported

that fewer than 10 households have been terminated from the program since the policy

went into effect in 2014.

Sanction waivers are granted on a case-by-case basis for extenuating circumstances (e.g.,

medical emergencies). The waivers are reviewed every 90 days.

Households are given 30 days to comply with the policy if they are not in compliance at

admission.

Households are subject to the work requirement at

When households are not in compliance at annual recertification, they receive a notice of

admission/move-in to public housing or HCV

violation and are given 14 days to comply.

programs.

Households who are noncompliant are given an opportunity to participate in LDCHA’s

LDCHA

Recertification is conducted annually and done by

FSS or ROSS-SC program to become compliant, but participation is voluntary.

PHA staff.

Households who remain noncompliant after referral to the FSS or ROSS-SC program

LDCHA does not monitor compliance between

can be sanctioned. Possible sanctions include a rent increase to full market rate and

annual recertifications.

termination from housing assistance. However, staff reported that LDCHA has never

terminated any household for noncompliance with the work requirement.

LDCHA provides a degree of rent relief to assisted households who experience loss of

earned income through sanction waivers, known as hardship rent reduction.

Monitoring is done by PHA staff during annual

When households are not in compliance, they are subject to rent based on imputed

LHA

recertification.

income. Households can request a hardship waiver, allowing them to pay the minimum

Households are required to provide at least six pay

rent for 90 days. The hardship waiver can be renewed and assisted households are not

stubs.

limited in the number of waivers allowed.

Monitoring was done by property managers. Annual

LMHA

recertification was done by property manager and

When not in compliance, LMHA moved households back into regular public housing

paired with quarterly review of employment status

units, if available; the housing authority had no formal process for sanction waivers.

done by case managers.

AH = Atlanta Housing. CHA = Chicago Housing Authority. DSHA = Delaware State Housing Authority. FSS = Family Self-Sufficiency. GED = General Educational Development. HACC = Housing Authority of Champaign County. HACSB = Housing Authority of the County of San Bernardino. HCV = housing choice voucher. LDCHA =

Lawrence-Douglas County Housing Authority. LHA = Lexington-Fayette Urban County Housing Authority. LMHA = Louisville Metro Housing Authority. MTW = Moving to Work. PHA = public housing authority. ROSS-SC = Resident Opportunity and Self-Sufficiency Service Coordinator.

36

A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Successes. PHA staff have observed increases in

wages, employment, workforce engagement, and

The most successful thing is that it really does

move individuals toward self-sufficiency. And

retention among assisted households subject to the

we’ve had individuals who started our program

work requirement policy. PHA staff also shared

that didn’t have a GED. They got their GED.

vignettes describing how some assisted households

They did job training; they got into employment

benefited from work requirement programs, were

and were able to move on successfully.

able to achieve their academic goals, completed

—DSHA Staff Member

employment trainings, and were successfully placed

in jobs.

Lessons Learned. All PHA staff interviewed

viewed the work requirement policy as valuable in

I would not recommend doing a work

requirement without providing internal

helping assisted households move toward self-

employment and education supports through FSS

sufficiency. Staff emphasized the importance of

and ROSS-SC. I would be philosophically

supportive services in support of the implementation

opposed to that because I don’t think that’s a fair

of the work requirement policy. Furthermore, some

application of a work requirement.

staff underscored that having a work requirement

—LDCHA Staff Member

policy establishes that public housing is temporary

while people get back on their feet. PHAs

highlighted several considerations as critical for successful implementation of the work requirement policy:

 Conducting a community needs assessment and research about the local job market to help tailor services to support assisted households.

 Educating assisted households and conducting public outreach about available support services.

 Getting buy-in from stakeholders, including tenants and staff, during development of the work requirement policy.

 Continuously monitoring the program to assess outcomes and outline potential changes to the policy.

 Having flexibility and patience in implementing and modifying the policy to achieve intended goals.

Overall, PHAs share similarities but also vary significantly in many aspects of their work requirement policies, as each PHA has adapted their work requirement to local population and labor market conditions.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

5. CONCLUSION

Two of the largest federal public benefit programs, Temporary Assistance for Needy Families (TANF) and Supplemental Nutrition Assistance Program (SNAP), have a work requirement policy as a condition of program eligibility and benefits, rationalized on the basis of reducing poverty through paid employment.

Beginning in 2018, several states adopted similar work requirement policies for Medicaid beneficiaries, although by 2022, those policies were no longer in effect. Similarly, over the past two decades, 9 of the initial 39 public housing agencies with Moving to Work (MTW) designations have implemented a work requirement policy. As of March 2022, seven of the nine MTW PHAs still had a work requirement policy in place.

Several studies have investigated the effectiveness of work requirement policies in fulfilling the policy goals across the four public benefit programs. Literature review findings for TANF, SNAP, and Medicaid revealed that the work requirement policies in those three programs caused many recipients to lose or experience an interruption in program benefits and failed to help people gain meaningful employment to move them out of poverty. Researchers have proposed to policymakers that to improve the employment outcomes of TANF and SNAP participants, work requirement policies need to focus on improving

participants’ skillsets through employment training such as on-the-job learning and connecting them to better-quality jobs to improve employment outcomes rather than requiring immediate engagement in required work activities. Because of the serious negative outcomes that have resulted from Medicaid’s work requirement policy, the Centers for Medicare and Medicaid Services (CMS) has rescinded approval for work requirements in all states that had implemented its policy in recent years.

Only one rigorous evaluation of the impact of a work requirement policy in HUD-assisted housing has been conducted (INLIVIAN in Charlotte, NC). This study has shown some promise, as the program demonstrated short-term improved employment gains and household income among the households that were subject to the work requirement policy. Other PHAs have assessed their work requirement policy by examining their outcome measures over time, but those studies were largely observational and lacked a comparison group.

To better understand the various perspectives on work requirement policies, the study team conducted interviews with eight key expert stakeholders and industry leaders in the housing policy community to gather their perspectives on the role of a work requirement in assisted housing. Although some stakeholders were opposed to the implementation of a work requirement policy in assisted housing, most agreed that if a work requirement policy were to be implemented, the policy should strive to increase assisted households’ employment and earned income so households can permanently move out of assisted housing. In addition, the consensus among the stakeholders was that comprehensive supportive services are crucial for the success of a work requirement policy and to reduce the adverse consequences for households subject to the policy. Several stakeholders expressed concern with framing the policy as a

“work requirement.” Those stakeholders noted that the term has negative connotations, is politically divisive, and does not reflect the support services provided to assisted households by MTW PHAs that have implemented a work requirement.

The study also collected and analyzed data from the nine MTW PHAs that have implemented a work requirement policy to date. The work requirement policies at each of the MTW PHAs share similarities but also vary substantially in terms of specifics, such as work activities, work hours, time limits, which participants are subject to the work requirement, and implementation procedures. However, the MTW

PHAs share a common goal: to promote economic self-sufficiency and quality of life of public housing 38

A Review of Work Requirement Policies in HUD-Funded Assisted Housing

assisted households (and reduce their residents’ dependence on government assistance). Each PHA has adapted its work requirement policy to the unique needs of the assisted households served and the local community. That adaptation has resulted in considerable variation in the implementation of the work requirement policy adopted by each MTW PHA. Case studies of each of the nine MTW PHAs that have implemented a work requirement policy are presented in appendix B.

Overall, the findings from this study contribute to a contextual understanding of how work requirements might be implemented in assisted housing, providing key insights into how each of the nine MTW PHAs have implemented the work requirements and highlighting key gaps in the existing knowledge base that can be explored in future studies.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

APPENDIX A: DETAILS OF LITERATURE REVIEW

The study team employed a multistep literature review process to describe Medicaid, Temporary Assistance for Needy Families (TANF), Supplemental Nutrition Assistance Program (SNAP), and

assisted housing (public housing and Housing Choice Voucher [HCV]) programs’ work requirements. The literature review process consisted of the following steps:

1. Searching the literature using approved search terms, including soliciting seminal literature from U.S. Department of Housing and Urban Development (HUD) subject matter experts and

reference lists.

2. Reviewing and screening identified literature using inclusion and exclusion criteria.

3. Reviewing full-text literature.

4. Summarizing, synthesizing, and interpreting final literature.

The following sections provide details regarding the team’s approach to searching the databases for peer-reviewed literature, state and federal government reports, and organization websites, including the process for screening and reviewing the identified literature and synthesizing and interpreting the included literature.

1. Searching Literature

In consultation with the Contracting Officer’s Representative (COR), the team developed initial search terms (such as the specific program names “SNAP,” “Medicare,” “TANF,” and “housing” with “work requirement”) to limit the search. Those search terms and inclusion and exclusion criteria (see exhibit A.3) were used to search for state and federal government reports and peer-reviewed literature.

Peer-Reviewed Literature

The team searched four electronic databases for peer-reviewed literature in December 2021 and January 2022: Academic Search Complete, PubMed, Web of Science, and JSTOR. Those databases catalog a wide array of peer-reviewed journals that publish content related to well-being and housing support programs.

Searches were restricted to articles published or written in the past 10 years (2011 or later) for TANF, SNAP, and Housing programs, with research conducted in the United States and available in English. For Medicaid, searches were restricted to articles published in 2016 or later. See exhibit A.1 for the search terms used for the peer-reviewed article search.

Exhibit A.1. HSA for NED Search Terms

Programs of Interest

Year

Geography

Language

Medicaid

2016 or

later

Temporary Assistance for Needy

Families (TANF)

AND

Work

United

Supplemental Nutrition

Requirement 2011 or

States

English

Assistance Program (SNAP)

later

Public housing

Housing Choice Voucher (HCV)

Exhibit A.2 provides the specific number of papers returned for each of the four databases searched before removing duplicates. In total, the preliminary searches initially identified 1,285 articles. Because 40

A Review of Work Requirement Policies in HUD-Funded Assisted Housing

initial searches in PubMed and JSTOR retrieved a number of Medicaid articles, the remaining searches focused on the other programs. After removing duplicate articles, 75 papers remained.

Exhibit A.2. Number of Papers Returned for Databases Searched

Database

Date of Search

Number of Papers Returned

(Before Duplicates Removed)

Academic Search Complete

11/22/2021–1/09/2022

66

JSTOR

11/22/2021–1/09/2022

559

PubMed

11/22/2021–1/09/20222

428

Web of Science

11/22/2021–1/09/20222

232

Total number of papers before duplicates were removed:

1,285*

Total number of papers after duplicates were removed:

75

*This number only includes results from Academic Search Complete, PubMed, and Web of Science.

In consultation with HUD, the research team decided to drop JSTOR as a source, as the most relevant articles from JSTOR were captured by the other three databases.

Organization Reports on their Websites

In consultation with the COR, the team identified the Urban Institute and Center on Budget and Policy Priorities (CBPP) as public programs having websites that contained relevant reports addressing work requirements that were not published in journals. In total, 35 reports were initially identified on the Urban Institute website and 23 reports on the CBPP website.

Reviewing and Screening Identified Literature

In total, the team reviewed 58 articles from organization websites and 75 articles from peer-reviewed literature databases (see exhibit A.3 for information regarding each program). The 2M Team then screened and reviewed this list of articles (with abstracts) using a standardized procedure. Using inclusion and exclusion criteria (see exhibit A.4), at least one trained team member reviewed the title, abstract, or both components of every publication identified through the peer-reviewed literature and organization report searches.

Exhibit A.3 | Articles and Reports Available for Full-Text Review for Each Program

Programs

Number of Papers Available for Full Text Review for Each Program

TANF

25

SNAP

26

Medicaid

38

Housing

15

Multiple

28

Exhibit A.4. Inclusion/Exclusion Criteria for Literature Review

Component

Inclusion Criteria

Exclusion Criteria

Housing

 TANF

 Other programs

Services

 SNAP

Programs

 Housing

 Medicaid

Topics of

 Work requirements

Interest

41

A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Component

Inclusion Criteria

Exclusion Criteria

Type of

 Observational

 Commentaries

Data/Analysis

 Qualitative

 Thought papers

 Program evaluation

 Raw data without analysis (for example,

 Experimental

financial data, infographics, caseload data,

participation rates)

 Infographics

 Caseload data

 Participation rates

 Systematic review

 Meta-analysis

Type of

 Reports to Congress

 Letters to the editor/opinion

Publication

 Federal reports

 Blogs

 State reports

 Websites/webpages

 Policy issue/briefs

 Dissertations/theses

 Promising practice

 Books

 Scholarly journals

 Contingency funds award

 Success story

 Working papers

Publication

 2011 or later

 Before 2011

Date*

 2016 or later (Medicaid only)

 Before 2016 (Medicaid only)

Country

 United States

 Any other country

Language

 English

 Any other language

*Note: This information applied only to peer-reviewed literature.

2. Reviewing Full-Text Literature

The team systematically tracked all literature reviewed and the reasons for exclusion, when applicable.

When the title, the abstract, or both met the inclusion criteria (based on exhibit A.4), it was flagged for a full-text review. For articles or reports that met the inclusion criteria for a full-text review, the following information was extracted, when available, to facilitate a final decision about inclusion using the same criteria as above but using the full-text information rather than just the title and the abstract.

 Citation

 Unit of analysis

 Included housing assistance and housing-

 Services and methods of service delivery

related services program(s)

 Challenges and barriers identified

 Population (and subpopulations of interest–for  Main theme

example, type of disability, housing situation

 Study design/methods and included variables

before housing assistance receipt,

 Findings, outcomes, and impacts

race/ethnicity, sex, income, geography, other

 Study implications and areas of gaps

community characteristics)

 Suggestions for future research

 Data source(s)

Differences between reviewers were resolved through discussion or consultation with another team reviewer. For example, if one reviewer thought a paper warranted a full-text review but the other reviewer excluded the same paper, those reviewers would discuss their reasoning for their decisions and arrive at a consensus. If an agreement could not be reached, a third reviewer was consulted. The screening and full-text review results from the 46 articles (see exhibit A.5) and reports that the team deemed relevant are summarized, interpreted, and synthesized in the Literature Review chapter of the report.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Exhibit A.5. Articles and Reports Cited in the Report for Each Program

Programs

Number of Papers Cited for Each Program

TANF

16

SNAP

11

Medicaid

13

Housing

6

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

APPENDIX B: CASE STUDIES OF MTW PHAS WITH A WORK

REQUIREMENT

 Atlanta Housing

 Housing Authority of Champaign County

 INLIVIAN (formerly Charlotte Housing Authority)

 Chicago Housing Authority

 Delaware State Housing Authority

 Lawrence-Douglas County Housing Authority

 Lexington-Fayette Urban County Housing Authority

 Louisville Metro Housing Authority

 Housing Authority of the County of San Bernardino

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Atlanta Housing

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

1. BRIEF BACKGROUND

Atlanta Housing (AH)—serving the City of Atlanta,

All target adults in public housing, HomeFlex,

Georgia20—is the largest public housing agency

and Housing Choice Voucher (HCV) programs

(PHA) in Georgia and the 10th largest PHA in the

are subject to AH’s work requirement policy.

United States. AH joined the U.S. Department of

Housing and Urban Development’s (HUD) Moving to Work (MTW) Demonstration Program21 in 2003

and instituted its work requirement policy in Fiscal Year (FY) 2005 (Atlanta Housing Authority, 2005).

AH established its work requirement with the goal to help households build economic capacity and stability, thus allowing them to reduce their dependency on housing assistance.

AH’s work requirement policy requires all target adults22 to work an average of 20 hours per week. Target adults are public housing or HomeFlex23 residents or HCV program participants who are between the ages of 18 and 61 years and who are neither elderly nor have a disability. 24 Adults categorized as elderly or who have a disability are exempt from this policy. Details about the policy are in Section 3, Description of the Work Requirement Policy.

AH served more than 26,000 households in FY 2021, with staff reporting that more than 8,600 of these households were subject to the work requirement policy (Atlanta Housing Authority, 2021). During the last 15 years, AH has significantly increased the number of assisted households it serves from about 19,500 households in FY 2005 to about 26,000 households in FY 2021. However, the number of

households needing housing assistance has also increased significantly during the same period, with more than 73,500 households currently on AH’s public housing, mixed communities, and HCV waiting lists compared with nearly 40,000 households who were on the waiting lists in FY 2005 (Atlanta Housing Authority, 2005, 2021).

This case study details AH’s work requirement policy as of December 2021, including the development and implementation of the policy, challenges, successes, and lessons learned. The study team collected the summarized information through interviews with AH staff and a review of PHA documents, such as annual reports, MTW plans, and other related documents and websites.

20 For more information about AH, see: https://www.atlantahousing.org/.

21 MTW, launched in 1996, is a HUD demonstration program that provides PHAs with the flexibility to design and test innovative local strategies. For more information about MTW, see https://www.hud.gov/mtw.

22 AH uses the term target adults instead of work-able adults. Staff explained that “AH moved away from the work-able term based on guidance from its legal department and some concerns expressed by its constituency and stakeholders that the term suggested that non-working individuals were disabled and potentially discriminated against.”

23 HomeFlex is AH’s MTW project-based voucher program.

24 Individuals who are between the ages of 16 and 17 years and are not enrolled in school are also subject to AH’s work requirement policy.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

2. DEVELOPMENT OF THE WORK REQUIREMENT POLICY

Motivation for Instituting the Policy. AH instituted its work requirement policy in FY 2005 as part of the PHA’s broader vision for its MTW program. That vision includes helping assisted households to move away from communities with concentrated poverty and into mixed-income communities where they can achieve self-sufficiency. Staff explained that before MTW designation, most assisted households served by AH lived in public housing sites that had concentrated poverty, which contributed to poor

socioeconomic outcomes for those households. Therefore, AH has focused its efforts on deconcentrating poverty in those communities to help assisted households thrive economically and socially.

Desired Policy Outcomes. The original goal of AH’s work requirement policy was to increase resident accountability and contribution to the rental payment. The policy has since evolved to helping assisted households achieve economic self-sufficiency, allowing them to reduce dependency on housing

assistance. 25 Staff noted that, although the goal has evolved, AH continues to hold residents and program participants accountable to the rent payment in preparation for life after housing assistance.

Concerns and Needs Considered During Policy Development. Before developing its work requirement policy, AH conducted an assessment of its assisted households to identify concerns and needs. The assessment identified the following concerns and needs of assisted households that AH considered during the development of its work requirement policy (Atlanta Housing Authority, 2004):

 High Poverty Rate—Most AH-assisted households had very low income; the average income was $8,874 per year. 26 Staff noted that the high poverty rate led to a generational cycle of assisted households living in public housing communities.

 Low Educational Achievement—Most assisted households lived in conventional public housing sites with high crime rates and low-performing schools with a high percentage of high school dropouts. Low educational achievement presented a significant barrier to assisted households’ readiness for the workforce.

 Childcare—Most assisted households were headed by single mothers, who often struggled to afford childcare services. Staff noted that those households also struggled to secure or maintain dependable transportation, which presented a significant barrier to employment.

Section 4, Implementation of the Work Requirement Policy, details the supportive services and resources AH provides to assisted households to address those barriers and challenges.

Entities Involved in the Development of the Policy. AH staff developed its work requirement policy under the leadership of Renée Lewis Glover, the Executive Director of AH at the time. AH also contracted with an urban planning research firm, Boston Consulting Group, to conduct an independent study of its efforts to deconcentrate poverty in assisted household communities. The study examined the quality-of-life changes for assisted households that had moved from one housing arrangement to another as AH demolished and reconstructed its properties (Atlanta Housing Authority, 2004). AH staff noted that findings from the study helped inform the development of the PHA’s MTW program, including the work requirement policy.

25 Staff reported that AH initiated the goal change in 2008 and finalized it in 2012 as part of AH’s business transformation plan, which included benchmarking outcomes of an independent study conducted by the Boston Consulting Group (BCG), an urban planning research firm. AH believed that the self-sufficiency index developed by BCG better measured the movement of families toward self-sufficiency. Staff noted that HUD has since developed standard metrics for all MTW PHAs’ consideration, and some of the metrics are similar to what AH was already measuring.

26 The average household income includes incomes for AH’s conventional public housing, mixed communities, and HCV households.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

3. DESCRIPTION OF THE WORK REQUIREMENT POLICY

AH’s work requirement policy requires that all target

Target Population (Inclusion/Exclusion Criteria)

adults, defined as individuals who are between the

ages of 18 and 61 years and do not have a disability,



All target adults in public housing, HomeFlex, and

HCV programs are subject to AH’s work

to be legally employed or self-employed in a

requirement policy.

legitimate business enterprise for an average of 20

 Elderly and disabled households are excluded.

hours per week. The policy applies across all AH

rental programs: public housing, HomeFlex, and HCV

programs. Individuals who are between the ages of 16

Activities That Count Toward Work

and 17 years and are not enrolled in school are also

Requirement

subject to AH’s work requirement policy.



Paid employment—

o Average of 20 hours/week.

AH provides support services to assisted households



Education/training—

subject to the work requirement policy through its

o Full-time enrollment in an accredited educational

Human Development Services Program to help them

institution or an approved training program.

develop self-reliance and enable them to realize better

o Combination of part-time education/training and

part-time paid employment.

financial, social, and health outcomes. AH provides

the services in partnership with local service providers, combining case management, service navigation, and coaching to assist families in attaining their goals. The program assists those families with goal setting, education opportunities, job and life skills training, counseling, money management, assessment services, and other additional support services that holistically serve the needs of the family. In addition, households receiving housing assistance for the first time must participate in AH’s Good Neighbor Program. Details about AH’s Human Development Services Program and Good Neighbor Program appear in section 4. Implementation of the Work Requirement Policy.

AH’s work requirement policy allows for education, job training, or both. For the education component, AH requires assisted households to be enrolled full time in an accredited educational institution or a training program approved by AH. Assisted households can also engage in a combination of part-time education or training and part-time paid employment. 27

In instances in which assisted households become noncompliant with the work requirement policy, AH

refers HCV households to the Human Development Services program for support services that will help them return to a compliant status. For public housing and HomeFlex households, onsite AH staff coordinate, facilitate, or make referrals to activities and service providers that can assist the households in returning to a complaint status.

Policy Changes. AH has implemented only one major policy change since the work requirement policy went into effect in FY 2005. Exhibit B.1 summarizes the policy change.

27 AH previously defined full-time and part-time employment as working 30+ hours/week and 16+ hours/week, respectively. It is unclear how AH currently defines part-time employment given the FY 2019 policy change highlighted in exhibit B.1.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Exhibit B.1. Key Policy Change Implemented by AH

Policy Change

FY

Rationale

AH realized that most of its assisted households were being

“penalized” for working in jobs in which employers would not

AH reduced the requirement

schedule their employees for 30 or more hours to avoid

for paid employment from 30+

triggering the requirement to provide insurance under the

hours/week to an average of

2019

Affordable Care Act (ACA). 28 Hence, many employers

20+ hours/week.

strategically scheduled their staff for fewer hours, especially

employers in service industries (e.g., restaurants, retail stores,

hotels), where work hours and schedules are flexible.

AH = Atlanta Housing.

Suspensions of the Policy and Associated Reasons for Suspension. In 2020, AH suspended enforcement of its work requirement policy for the first time since inception due to the COVID-19 pandemic. The enforcement of the policy remained suspended as of December 2021. AH did not assess sanctions on assisted households during that period for failure to comply with the work requirement policy, continuing to provide them support services. Staff noted that they follow various pandemic protocols—including local, state, and Centers for Disease Control and Prevention’s guidance on COVID-19—to help inform their decision on when to reinstate the enforcement elements of the work requirement policy.

28 ACA, sometime called Obamacare, is a federal health care statute that Congress enacted and signed into law in 2010. For more information about ACA, see: https://www.healthcare.gov/where-can-i-read-the-affordable-care-act/.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

4. IMPLEMENTATION OF THE WORK REQUIREMENT POLICY

Support Services

Working with the local partners listed in exhibit B.2, AH

Support Services Provided by AH and Its

provides a range of supportive services and resources to

Community Partners

help assisted households achieve economic self-



Workforce development services.



Financial literacy.

sufficiency. Staff noted that AH designs supportive



Support for basic needs.

services to holistically address barriers and challenges



Aging well programs.

faced by assisted households. For example, when AH



Afterschool programs.

refers an unemployed individual to the Human



Homeownership programs.

Development Services team, the team focuses on



Good Neighbor Program.

addressing the barriers and challenges faced by the individual as well as by the individual’s entire household. If the individual is a caregiver to an elderly family member, AH can provide a continuum of supportive services to both the individual and the elderly family member. AH’s support services include the following:

 Workforce Development Services. Various community partners provide workforce development services to assisted households who are unemployed or underemployed.

o Essential skills and employment preparation training: Established partnerships with nine organizations that provide job training and placement services as well as entrepreneurial

training and coaching.

o Job search and placement services: Workforce development organizations that help assisted households search for work in target industries such as construction, health care, hospitality, retail, safety and security, and transportation.

o Job coaching and retention support: Workforce development organizations that help

assisted households find and maintain employment.

 Financial Literacy. Financial literacy providers offer various financial classes, including banking relationships, budgeting, credit counseling or repair, and retirement or wealth building, among others.

Those services are provided through referral from AH.

 Support for Basic Needs. Various community partners help assisted households address basic needs, including childcare, transportation, clothing, utilities, and health care, among others. Those services are also provided through referral from AH.

 Aging Well Programs. Various community organizations empower older assisted households to be active by providing them with opportunities for social engagements and connections to family and friends. AH also connects those households to resources that promote wellness, such as healthy eating and mental health resources.

 Afterschool Programs. Youth development organizations such as the Boys and Girls Clubs of Metro Atlanta provide afterschool programs to assisted households.

 Homeownership Programs. AH operates a Down Payment Assistance (DPA) Program that helps eligible, qualified households earning up to 80 percent of the Area Median Income to purchase their first home. Households can combine AH’s DPA award with other assistance programs to help

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

maximize housing affordability. In addition, AH operates an HCV Homeownership Program that

allows qualified assisted households to use their HCV subsidies toward monthly mortgage payments.

AH no longer accepts new families into the HCV Homeownership Program but continues to support households who were already in the program. 29

 Good Neighbor Program. AH initially developed the Good Neighbor Program to help assisted households transition from low-income communities into vibrant, mixed-income communities, but the program has grown since its inception. Although it continues to cover a variety of topics—

including civic awareness and engagement, neighborly values, and effective tenant-landlord

relationships—the program has evolved to include comprehensive life skills. AH designed the current training curriculum to educate participants on tenant rights, landlord relationships, soft skills, self-efficacy, communication, and problem solving to promote a successful tenancy. In addition to

addressing those topics, the program offers a variety of training modules to further develop and enhance assisted households’ life skills during and after their tenure in assisted housing. Training modules offered include improving self-reliance and personal responsibility, homeownership, and parenting, among other topics. The Martin Luther King Senior Community Resources Collaborative, AH’s contracted partner for the Good Neighbor Program, provides program services.

Exhibit B.2. Contracted AH Service Providers

Name of Partner

Type of Organization

Supportive Services Provided

1. Mercy Care

Behavioral health agency

Behavioral health counseling

2. Atlanta Center for

Workforce development

Comprehensive workforce

Self-Sufficiency

provider

development training

3. City of Refuge, Inc.

Workforce development

Comprehensive workforce

provider

development training

4. WorkSource Atlanta

Government agency

Job readiness, job training, job search

and placement, and career counseling

5. Urban League of Greater

Workforce development

Job placement, adult literacy, and

Atlanta

provider

vocational counseling

6. Boys and Girls Clubs of

Metro Atlanta

Youth organization

Afterschool program

7. Young Men’s Christian

Associations (YMCA)

Youth organization

Afterschool and summer programs

8. Fulton County

Seniors: in-home, community-based

Government Senior

Government agency

programming and transportation for

Services

AH residents

9. Liberty Group Senior

Services

Senior citizen organization

Comprehensive programs and

activities for seniors

10. Martin Luther King

Senior Community

Economic support organization Economic mobility education and

Resources Collaborative

counseling

AH = Atlanta Housing.

29 AH directs new HCV households who are interested in homeownership to the DPA Program.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

In addition to providing referrals to the contracted service providers listed above, AH also engages in collaborative efforts with a variety of noncontracted organizations that provide housing, essential services, senior services, and additional supportive services to support the health and well-being of program participants. Formal and informal partnerships focus on three main areas of collaboration: service planning, service delivery, and advancing intended agency outcomes.

Compliance Monitoring

Process for Monitoring Compliance. AH requires assisted households to recertify continued eligibility annually, biennially, or triennially depending on their program compliance status. AH recertifies households that maintain steady compliance less frequently than those who fall out of compliance on a regular basis. AH staff complete recertification for assisted households in the HCV program, and property managers conduct recertifications for assisted households in the public housing and HomeFlex programs.

For public housing and HCV programs, AH gives assisted households who lose employment 90 days to meet compliance requirements; otherwise, they may be considered noncompliant and referred to the Human Development Services team or other employment support resources. For the HomeFlex program, AH gives assisted households up to 12 months to become compliant with the policy. In all cases, AH may extend the cure period when households present evidence of active search for employment or at the discretion of AH. AH may also grant rent relief on a case-by-case basis to assisted households who lose employment due to factors beyond their control.

Work Requirement Policy Compliance Rate. AH staff reported that before the COVID-19 pandemic, the average compliance rate for their work requirement policy was about 71 percent. Staff explained that AH

calculates the compliance rate by taking the number of target households compliant with the policy and dividing it by the total target households. Exhibit B.3 illustrates the compliance rate calculation.

Exhibit B.3. AH’s Compliance Rate30

Fiscal Year End (FYE) Compliant/Employed

Households

Target Households

Compliance Rate

2020

5,917

8,205

72%

2021

5,712

8,606

66%

2022*

5,853

8,576

68%

AH = Atlanta Housing.

*As of December 31, 2021.

The AH goal is to achieve an average compliance rate of 75 percent each year. However, staff noted that they have learned about several factors that currently affect the employment expectations of assisted households and achievement of the compliance rate that were not present 15 years ago, when the policy was instituted. 31 As a result, AH will reassess the 75-percent benchmark during its 2023 MTW planning process and may revise the benchmark to one that is more reflective and representative of the current workforce and market conditions.

Sanctions for Noncompliance. Assisted households who are noncompliant risk losing their housing assistance. However, termination from the program is a last resort and a rare occurrence. AH offers intensive supportive services to noncompliant households designed to support households getting back 30 AH provided the data highlighted in exhibit B.3.

31 AH did not provide details on the current factors that affect employment expectations of households and achievement of the compliance rate.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

into compliance. Support services include referrals to available jobs, workshops to upskill in technology, application completion, or interview techniques, and “Dress for Success” services. AH prefers to exhaust alternative measures before exercising end-of-program options. Staff explained that over the past 8 years, AH has terminated only 64 households from the program for failure to comply with the work

requirement, including nonparticipation in referral service activities.

Sanction Waivers. Staff noted that AH does not provide waivers per se because it administers a local residency preference to ensure that low-income Atlantans who reside or work in the city have priority for housing assistance. AH expects participating households to maintain employment or remain in

compliance with their service plan for continued participation in the PHA’s housing assistance programs.

In some instances, AH may offer a Caretaker Exemption as a reasonable accommodation for target adults who care for homebound family members. AH may also exercise a Special Admissions Exemption for HAVEN households32 on the basis of certain admission criteria or status of the household.

32 HAVEN is AH’s supportive housing program that provides persons experiencing or at risk of homelessness with stable housing, intensive case management, and supportive services. For more information, see

https://www.atlantahousing.org/wp-content/uploads/2020/09/Supportive-Housing-Program-Offerings-1.pdf.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

5. CHALLENGES, SUCCESSES, AND LESSONS LEARNED

Challenges Implementing the Work Requirement Policy. Staff reported that AH faces several implementation and ongoing administrative challenges to the work requirement policy beyond the challenges of changing assisted households’ mindsets. Staff described challenges including difficulty finding affordable childcare or open slots available and accessible to low-income households; lack of dependable transportation, which prevents some households from obtaining or maintaining employment; and assisted households who lack employment and conflict resolution skills. AH staff believed that the primary challenge in implementing the work requirement policy was due to limitations of its network of support services providers. Staff explained that, over the years, they have realized the importance of having a network of service providers that can address the variety of barriers and challenges faced by assisted households, including literacy barriers, poor work culture backgrounds, limited work experience and expectations, and undiagnosed mental health issues, among others. In addition, staff emphasized that networks of support services providers must be able to handle the volume of referrals from PHAs.

Further, those networks should be equipped to provide long-term support services that address generational and situational poverty among assisted households.

Successes of the Work Requirement Policy. Staff noted

Key Success of AH’s Work Requirement

AH’s biggest success is the program’s effectiveness in

Policy

opening a greater array of economic opportunities for

89 percent of assisted households pay above

assisted households and helping them move out of poverty.

AH’s minimum rent of $125 per month.

They reported that, as of FY 2021, 89 percent of all assisted households across all programs were paying above AH’s minimum rent of $125 per month. Staff also noted that they monitor a set of performance metrics that provide a clearer indication of success (see exhibit B.4).

Exhibit B.4. AH’s Performance Metrics

Mid-

Performance Metric

FYE 2018 FYE 2021 % Change Year* FY % Change

2022

HHs paying 100% of Their

Rent—Zero Housing Assistance

76

103

36%

137

33%

Payment

Average HH Earned Income

$20,935

$22,397

7%

$22,613

1%

Average Tenant Rent to Owner

$238

$305

28%

$319

5%

AH = Atlanta Housing. FY = Fiscal Year. FYE = Fiscal Year End. HH = household.

*As of December 31, 2021.

Note: AH provided the data highlighted in exhibit B.4. Staff noted that, due to multiple system changes, AH had data only since FYE 2018

readily accessible.

Assessment of the Policy. Staff noted that AH is not required to conduct a third-party evaluation of its work requirement policy or its MTW program. However, AH has conducted several internal reviews and third-party studies of its broader MTW program. Those studies have examined the following (Atlanta Housing Authority, 2011):

 The effectiveness of AH’s approach in deconcentrating poverty.

 The impact of AH’s revitalization efforts at various public housing sites.

 The economic impact of AH’s mixed-income communities revitalization efforts.

 The outcomes of assisted households that relocated to private rental markets with the HCV

program.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

 The impact of public housing transformation on receiving communities.

Lessons Learned During Implementation and Monitoring of the Work Requirement Policy. Staff stated that PHAs should develop a work requirement policy with the goal of helping assisted households achieve long-term self-sufficiency, ensuring that program participants contribute to their rental payments and to develop a strong work culture among assisted households. Staff emphasized that a work requirement policy should consider the following: PHA jurisdiction, availability of jobs, job readiness of assisted households, the distance of job locations, availability of affordable childcare and open slots for assisted households, incentives that match the intent of the policy, and the mode of transportation used by assisted households (whether mass transit or “community taxis” are available and whether those modes of transportation are reliable).

Staff recommended that PHAs thinking about implementing a work requirement policy also consider potential barriers and challenges for assisted households with undiagnosed mental health issues, in which those who want to work and be active may not be aware that they have limited capability to work full time (i.e., 32+ hours) or long term (i.e., 24+ consecutive months). Staff also stated that monitoring compliance with the work requirement policy adds a heftier administrative burden to AH’s operational process than originally anticipated because opportunities exist for assisted households to “game” the system. They noted that PHAs must understand the administrative burden associated with monitoring compliance with a work requirement policy and to make long-term preparations to achieve success.

Overall, staff noted that the work requirement program has played a critical role in helping many assisted households move away from communities with concentrated poverty and into mixed-income

communities where they can achieve self-sufficiency. Staff credit the success of the program to AH’s holistic approach to the provision of supportive services.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Housing Authority of Champaign County

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

1. BRIEF BACKGROUND

The Housing Authority of Champaign County

The LSS requirement applies to all able-bodied

(HACC) is a municipal corporation organized

individuals ages 18 through 54 years in each

pursuant to the Illinois Housing Authority Act,

household except for elderly people and

covering the County of Champaign, Illinois. 33

individuals with disabilities.

HACC provides affordable housing to low- and

moderate-income households through project-based vouchers (PBVs) and housing choice vouchers

(HCVs). By December 2018, HACC had converted the final public housing units to private ownership under the Rental Assistance Demonstration, thus zeroing out the public housing program. As of January 2022, HACC administers nearly 1,700 HCVs and 340 PBVs to serve more than 2,000 families. 34

HACC became one of 39 public housing authorities (PHAs) to be designated as a Moving to Work

(MTW) agency in 2010. In 2016, HACC signed a new agreement with the U.S. Department of Housing and Urban Development that ensures it remains in the MTW program until 2028. HACC identified three primary goals that drive its MTW activities:

1. Operational efficiency through innovation: Streamline business processes and implement advanced technological solutions that lead to operational cost efficiencies and enable reallocation of resources to local initiatives and strategies.

2. Self-sufficiency: Provide incentives to motivate families to actively seek financial independence and transition from dependency on housing subsidy.

3. Expand housing opportunities: Develop new housing in rural communities that HACC does not serve by leveraging private capital to ensure HACC’s economic variability and sustainability.

HACC implemented a mandatory Local Self-Sufficiency (LSS) requirement under its MTW program in 2013 (although HACC had approved it in 2011). HACC requires participation in the LSS program as a condition of eligibility for new admissions and continued occupancy for existing participants. This requirement applies to all able-bodied individuals—described as those ages 18 through 54 years—in each household except for elderly people and individuals with disabilities. In addition, HACC expects households to exit the program at the end of the 8-year term limit. HACC can also terminate a household from receiving assistance if it falls out of compliance with the LSS requirement policy (details about the LSS requirements are in section 3, Description of the Work Requirement Policy) (HACC, n.d.d).

This case study details HACC’s work requirement policy as of December 2021, including development and implementation of the policy, challenges, successes, and lessons learned. The study team summarized the information collected through interviews with HACC staff and a review of PHA documents, such as annual reports, MTW plans, and other related documents, and on HACC’s website. The following

sections describe details about the policy’s development, implementation, challenges, successes, and lessons learned.

33 See the HACC website at https://hacc.net/about-us/.

34 The HACC annual reports can be found here: https://hacc.net/2020-annual-report/.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

2. DEVELOPMENT OF THE WORK REQUIREMENT POLICY

Motivation for Instituting the Policy. HACC designed the LSS requirement policy to motivate all able-bodied individuals to seek self-sufficiency35 and to exit housing assistance so that HACC can offer assistance to other low-income families. In 2016, HACC incorporated the 8-year term limit. HACC had always envisioned it as an integral component of its work requirement policy but wanted to first introduce and monitor the work requirement policy before introducing the term limit.

Desired Policy Outcomes. The desired outcomes of the LSS requirement are—

1. Participants are well-paid and have secure, stable employment.

2. Households’ income increases annually and they become financially independent.

Concerns or Needs Considered During Policy Development. Although HACC approved the LSS

program in 2011, it did not implement the policy until January 1, 2013, because many community leaders, stakeholders, and residents were concerned that complying with the employment requirement would be challenging due to the economic conditions, limited availability of jobs, and lack of transportation. To address those concerns, HACC developed a new strategy allowing participants ample time to prepare for employment (HACC, n.d.c).

Entities Involved in the Development of the Policy. HACC Interim Executive Director, Cindy Herrera, was involved in developing HACC’s work requirement policy with researchers from University of Illinois at Urbana-Champaign (UIUC). Ms. Herrera was also a consultant for HACC when it developed its MTW

plans. UIUC has assisted HACC with annual reports from 2011 through 2018 and has undertaken

evaluation efforts each year.

35 HACC defines self-sufficiency as “demonstrated behavior that exhibits personal accountability and financial responsibility through consistent (more than 12 months) employment appropriate to the maximum skill level achievable by the individual.”

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

3. DESCRIPTION OF THE WORK REQUIREMENT POLICY

HACC instituted its work requirement policy in 2013

Target Population (Inclusion/Exclusion Criteria)

through the mandatory LSS program for all residents



All able-bodied individuals ages 18 through 54

(public housing36 and HCV participants). Under the

years must meet the work requirement.

LSS program, HACC requires all able-bodied

 Elderly people and individuals with disabilities are

individuals ages 18 through 54 years to actively

exempt from this requirement.

 Sole caregivers (providing full-time care for an

pursue activities to achieve economic self-sufficiency.

elderly parent or disabled or sick child) are also

The program counts three activities toward the work

exempt from this requirement if HACC grants a

requirement: work 25+ hours/week (which HACC

waiver.

increased from 20+ hours/week in 2016); be enrolled in a training or educational program that offers a degree or certificate on a full-time basis (as defined by the institution); or be self-employed, including home childcare providers as long as they have an annual income equivalent to 1,300 hours times the minimum wage for the state of Illinois. Household members who are unemployed are encouraged to enroll on a full-time basis in an educational program

Activities That Count Toward Work

that offers a degree or certificate to prepare them to

Requirement

obtain employment and become economically self-



Employed 25 hours or more per week and meeting

sufficient; they must complete 75 percent of all

the minimum earned income requirement.

required courses on an annual basis to be considered



Enrolled full-time in an educational or training

program.

as making successful progress toward the degree or



Self-employed and meeting the minimum earned

certificate (HACC, n.d.d). HACC’s original policy

income requirement.

also required household members ages 5 through 18 years to be enrolled in and attend school, but HACC

dropped that condition in 2018 because they could not access attendance documentation from the local school district to monitor members.

Term Limit—Starting January 1, 2016, HACC approved and established an 8-year term limit on households receiving housing assistance after their first annual recertification. Households may face assistance termination during the 8-year term if they fail to comply with all the work requirements (including the income requirement discussed below).

Income Requirement—In 2019, HACC based its work requirement policy on annual earned income instead of the required number of hours (25+) per week, basing the minimum earned income for

compliance on the number of years the household has received assistance and the annual median income (AMI) for Champaign County. According to staff, household members who meet the required number of hours per week should meet the annual earned income at the minimum wage rate. HACC implemented the earned income requirement to provide flexibility for those who earned at a higher rate but worked fewer hours (exhibit B.5). HACC increases the earned income requirement by 5 percentage points or more each year to prepare participants to exit the program at the end of the 8-year term limit.

36 By December 2018, HACC had converted all public housing units to private ownership under the Rental Assistance Demonstration program, so the LSS requirement applies only to all HCV residents.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Exhibit B.5. HACC Minimum Earned Income Requirements for Each Year in the Program, 2022

Years on Assistance

Year 1

Year 2 Year 3-4 Year 5-6 Year 7

Year 8

Minimum Earned Income

$10,368 $14,688 $19,008 $24,192 $31,104 $38,880

% of Champaign County AMI

12%

17%

22%

28%

36%

45%

AMI = annual median income. HACC = Housing Authority of Champaign County.

Description of the Program Implementation: The LSS program requires the head of household to develop a self-sufficiency plan that identifies goals and objectives for each household member to participate in the program. 37 HACC holds the head of household accountable for the household’s overall compliance. During annual recertification, LSS program staff provide households with information on where they are within the 8-year term-limit window and discuss their exit plans from the program so that it is a planned event.

LSS coordinators work with program participants in the development of an Individual Training and Services Plan that aligns with the head of household’s self-sufficiency plan. The coordinator ensures that every participant is linked to supportive services they need to achieve their economic self-sufficiency goals.

Policy Changes. HACC has approved policy changes in the LSS program since it approved the work requirement policy in 2011 and implemented it in 2013. Exhibit B.6 summarizes key policy changes.

Exhibit B.6. Key Policy Changes Implemented by HACC

Policy Change

Fiscal

Year Rationale

1. The work requirement applied to able-bodied

heads of household, who were required to

engage in work-related activities for at least 20

2011

HACC approved but never implemented this change.

HACC added the age limit in 2012.

hours/week.

2. HACC expanded the work requirement to

include all able-bodied adults ages 18 through

2013

This was the year of implementation.

54 years in the household.

3. HACC requires all nonexempt household

members to be employed for 25 hours or more

per week or be enrolled in an educational

2016

This change ensures that the participants meet their self-

sufficiency goal.

program.

HACC had always envisioned term limits as a

component of its LSS program but wanted to first

4. HACC established the 8-year term limit.

2016

implement the work requirement. Term limits also allow

individuals to move off the waiting list so that HACC

can serve them.

5. HACC dropped the requirement for members

ages 5 through 18 years to be enrolled and

2018

HACC could not access attendance documentation from

attend school.

local school districts.

6. HACC implemented the minimum annual

This change ensured that the participants progressed

earned income criteria (instead of the number of 2019

toward their self-sufficiency goal and were able to exit

hours employed).

the program at the end of the 8 years.

7. HACC implemented financial incentives of

$2,000 per year for households who meet the

2019

This change incentivizes households to meet self-

sufficiency goals. In addition, such an incentive or an

37 HACC gave the heads of households until the end of 2012 to develop a self-sufficiency plan. If a new-admission household is not compliant with LSS requirements before submission of a Request for Tenancy Approval, the household must meet with an LSS case worker and develop a self-sufficiency plan.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Policy Change

Fiscal

Year Rationale

LSS requirement within a calendar year.

escrow account may be helpful to families’ successful

Households accrue credits, and HACC pays

transition from housing assistance, including helping

only upon the household’s voluntary exit from

those families interested in homeownership after exit

the program in good standing or upon expiration

(this change aligns with UIUC’s recommendation for

of the 8-year term limit. The household forfeits

HACC) (HACC, n.d.b).

all credits if the household is terminated from

the program for cause or ports to another

jurisdiction for any reason.

8. HACC implemented a mandatory job-retention

training program for individuals who had lost

Many individuals had difficulty maintaining employment

employment more than once. HACC requires

(this change aligns with UIUC’s recommendation for

those individuals to enroll, attend, and complete 2019

HACC to identify additional resources to transition to

a job-retention program (as required by the LSS

long-term employment) (HACC, n.d.a).

case manager).

HACC = Housing Authority of Champaign County. UIUC = University of Illinois at Urbana-Champaign.

Suspensions of the Policy and Associated Reasons for Suspension. HACC has not suspended its work requirement policy since its implementation. Beginning March 13, 2020, HACC closed its office to the public due to the COVID-19 pandemic and postponed appointments. However, HACC continued to

accept vital documents through email, fax, or drop box. To provide efficient services to clients, HACC

began hosting virtual online briefings on April 15, 2020 (HACC, n.d.c).

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

4. IMPLEMENTATION OF THE WORK REQUIREMENT POLICY

Support Services

The LSS program aims to promote work, educational

Support Services Provided by HACC

attainment, or both for all assisted households subject to



Case management.



Employment services.

the work requirement policy through the provision of case



Education services.

management and other community-provided supportive



Financial support.

services designed to help households achieve economic



Childcare support.

independence. A selected set of community partners to HACC is shown in exhibit B.7. The supportive services are summarized below.

 Case Management. Case management is a critical feature of the LSS program, and it is available to all households. However, if a household falls out of compliance, HACC requires the head of household to meet with an LSS specialist first to ensure that noncompliance is not due to missing documentation. If the family needs additional services to get back into compliance, the head of household works with the LSS coordinator, who ensures that the family is connected with

necessary supportive services. The case manager then works closely with the household and

follows up to ensure that the household gets back into compliance with LSS requirements. Any

household that is not compliant with the LSS requirement has 90 days to get back into

compliance.

 Employment Services. The YouthBuild program helps at-risk youth complete high school or equivalent degrees and earn credentials recognized by industries for in-demand occupations

(HACC, n.d.c). The YouthBuild Pre-Apprenticeship program provides work opportunities for

youth to gain work experience. HACC coordinates with development partners and contractors to

place eligible participants on construction sites so they can work with and learn from skilled tradesmen. In addition, HACC provides employment referrals to eligible households and holds

workshops to assist with writing a resume and cover letter and developing interview skills.

 Education Services. Parkland College and UIUC support families in the community that are in need of academic assistance. During the COVID-19 pandemic, students from UIUC offered

virtual tutoring and homework assistance to needy students (HACC, 2021). In addition, HACC

provides counseling to participants seeking higher education opportunities.

 Financial Support. Illinois Commitment provides scholarships and grants to students at the University of Illinois to cover tuition and other campus expenses. The cost of room and board is not included in the financial aid package, but HACC offers an Illinois Commitment Student

Voucher that covers the cost of living on campus in student dormitories. Students who are Illinois residents ages 17 to 24 years with a family income of $61,000 or less can apply for this

assistance.

 Childcare Support. Some local agencies provide workshops to help participants find local childcare providers. If families reach out to the HACC office for assistance on childcare, HACC

links them with childcare providers.

 SHIFT. In 2020, HACC implemented the SHIFT Program, which assists families that are LSS-compliant but have not yet achieved a level of self-sufficiency adequate to exit the HCV program.

The SHIFT program is funded through the Family Self-Sufficiency Grant and focuses primarily

on assisting heads of households in developing skills that will lead to higher-paying employment opportunities (HACC, n.d.d).

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Exhibit B.7. Selected HACC Implementation Partners

Name of Partner

Type of Organization

Supportive Services Provided

Helps at-risk youth earn industry-recognized

1. YouthBuild

Youth and community

development program

credentials, provide work opportunities to

youth

2. Parkland College

Educational institution

Provides academic support to students

3. UIUC

Educational institution

Provides academic support to students

4. Illinois Commitment Financial aid package

Provides scholarships and grants for students

at UIUC

HACC = Housing Authority of Champaign County. UIUC = University of Illinois at Urbana-Champaign.

Compliance Monitoring

Process for Monitoring Compliance. HACC requires all households with nonexempt members to show proof of compliance with the LSS requirement to the property manager or HCV staff at annual

recertification. Households usually present proof of employment to HACC for assessment, and staff follow up to review household’s pay stubs. HCV staff refer noncompliant households to an LSS

specialist, who follows up for any missing documents. If the household provides no documentation, the LSS specialist works closely with the household to ensure compliance with the LSS requirement.

Work Requirement Policy Compliance Rate. Of the 1,817 households HACC served in 2017, 381 (17

percent) transitioned to self-sufficiency, 454 (25 percent) were exempt from work requirements, and 984

(54 percent) were active LSS households. Among the active LSS households, 89 percent were compliant with the work requirement policy, and only 11 percent of the households were noncompliant. In 2021, HACC terminated five households from the program due to noncompliance.

Sanctions for Noncompliance. If a nonexempt household falls out of compliance with the work requirement policy, HACC gives the household 90 days to come into compliance by either finding a job or enrolling in an education program. If the household fails to comply during that window of time, HACC

proposes the household for termination from the LSS program. The household has the opportunity for a hearing at that stage.

Sanction Waivers. HACC can grant exemptions to the work requirement policy and term limits to a household on a case-by-case basis for two reasons: medical and sole caregiver waivers.

• Medical Waiver—HACC may grant a medical waiver (after third-party documentation from a doctor) to an individual who cannot work and is in recovery due to an injury, pregnancy, health concerns, temporary or permanent disability, or other similar circumstances.

• Sole Caregiver Waiver—HACC may grant a sole caregiver waiver to an individual who cannot work because he or she is providing full-time care for an elderly parent, a sick child, or a child with a disabling condition in the household, for example.

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5. CHALLENGES, SUCCESSES, AND LESSONS LEARNED

Challenges Implementing the Work Requirement Policy. HACC staff reported that implementing the work requirement policy was initially challenging, but staff notified all households about the pending policy change 1 year in advance and helped them evaluate and address any barriers that might hamper their compliance with the policy. Also, staff noted that HACC makes new households aware of the requirements when they enter the program, so implementation of the work requirement policy has become less challenging over time. According to HACC staff, the most difficult part of implementation is that some household members are turning 18 or 19 but not meeting the required amount of earned income. HACC has discussed this specific challenge internally and intends to make adjustments in their future plans.

Successes of the Work Requirement Policy. HACC staff

Key Success of HACC’s Work

believe that the work requirement policy is successful

Requirement Policy

overall. By the end of 2020, 630 households had fully



Between 2014 and 2020, 630 households

transitioned to self-sufficiency over the 6-year period, with

transitioned to self-sufficiency.



Average LSS household income increased

an average of 105 households per year exiting housing

by 42 percent between 2014 and 2020.

assistance. In addition, the LSS program led to a substantial



In 2021, 19 youths who were part of the

increase in earned income, with average household income

YouthBuild program graduated from high

increasing by 42 percent since the program’s

school or received educational certification.

implementation (HACC, n.d.c).



By 2021, 81 households enrolled in the

SHIFT program accomplished 88 goals and

Assessment of the Policy. UIUC conducted an evaluation of

earned financial incentives totaling more

than $28,000.

the HACC program from 2012 to 2020 and found that,

initially, heads of household faced major barriers to employment, such as having a large number of children, having a felony conviction on their record, and having limited access to transportation and childcare. The study also found that older participants with higher annual income were more likely to achieve self-sufficiency and graduate from the LSS program. In addition, the study noted that households with fewer dependents and who stay in the LSS program for a longer time had a higher likelihood of leaving the program because of term violation (HACC, 2019).

Lessons Learned During Implementation and Monitoring of the Work Requirement Policy. Staff indicated that the biggest lesson they learned was to have related supportive services in place and to make sure that households are aware that those services are free so their families can take advantage of the services and comply with the work requirements.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

INLIVIAN (formerly Charlotte Housing Authority)

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1. BRIEF BACKGROUND

INLIVIAN, formerly known as the Charlotte

At least one work-able adult at all households that

Housing Authority, is a public housing agency

participate in the Housing Choice Voucher or

(PHA) in North Carolina that serves Charlotte and

Project-Based Voucher program is subject to

Mecklenburg counties. 38 INLIVIAN joined the U.S.

INLIVIAN’s work requirement policy.

Department of Housing and Urban Development’s

(HUD’s) Moving to Work (MTW) Demonstration Program39 in 2007 and instituted a work requirement policy in 2014. 40 The goal of INLIVIAN’s work requirement policy is to help assisted households make progress toward economic self-sufficiency.

INLIVIAN’s work requirement policy is paired with rent reform41 to incentivize assisted households to increase their earnings. The policy requires at least one “work-able adult” at all households that participate in the Housing Choice Voucher (HCV) or Project-Based Voucher (PBV)42 programs to work at least 20 hours per week or participate in approved work-related activities. Work-able adult is defined as an individual who is between the ages of 18 and 61 and is neither elderly nor has a disability. Adults categorized as elderly or who have a disability are exempt from this policy. Details about the policy are provided below in Section 3, Description of the Work Requirement Policy .

In fiscal year (FY) 2019, INLIVIAN served approximately 7,800 households and had about 13,500

households43 on its waiting lists (INLIVIAN, 2019). Staff reported that, as of December 2021, about 3,600 households were subject to the work requirement policy.

This case study details INLIVIAN’s work requirement policy as of December 2021, including the development and implementation of the policy, challenges, successes, and lessons learned from implementing a work requirement policy. The information summarized was collected through interviews with INLIVIAN staff and a review of PHA documents, such as annual reports, MTW plans, and other related documents and websites.

38 For more information about INLIVIAN, see http://www.inlivian.com/.

39 MTW, launched in 1996, is a HUD demonstration program that provides PHAs with the flexibility to design and test innovative local strategies. For more information about MTW, see https://www.hud.gov/mtw.

40 INLIVIAN’s work requirement was proposed in 2010 and approved in 2011, but implementation was delayed until January 2014 due to local economic conditions.

41 Rent reform under the MTW program allows PHAs to change policies that determine the amount of rent paid by assisted households by moving away from the traditional 30 percent of adjusted income calculation. INLIVIAN changed its rent calculation to a stepped rent structure, in which rents are gradually increased (or, in the case of HCV, subsidies are decreased) on the basis of a fixed schedule. In FY 2019, INLIVIAN set assisted households’ income bands at $2,500 increments, with the stepped rent being 30 percent of the low end of the range. For example, in a $5,000–$7,500 annual income band, the low end of $5,000 is divided by the 12 months of the year and multiplied by 30 percent. The total rent payment required would be $125.

42 INLIVIAN converted all its public housing units to PBV units under HUD’s Rental Assistance Demonstration (RAD) program.

For more information about the RAD program, see https://www.hud.gov/RAD.

43 INLIVIAN allows assisted households to sign up on multiple waiting lists (for example, HCV and PBV), so this number may include duplicates.

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2. DEVELOPMENT OF THE WORK REQUIREMENT POLICY

Motivation for Instituting the Policy. INLIVIAN instituted its work requirement policy in 2014. The policy was proposed in 2010 and approved in 2011, but implementation was delayed until 2014 due to a spike in unemployment in the local area. Staff reported that they were motivated to implement a work requirement policy because of their MTW designation and a desire to promote self-sufficiency among assisted households. INLIVIAN believes that assisted households who can work should work, but they do not have an expectation that people will exit housing assistance in a specific time frame. Staff noted that Charlotte has an affordable housing crisis—even a full-time job at minimum wage does not provide sufficient income for many households to pay rent without some type of housing assistance.

Desired Policy Outcomes. The goal of INLIVIAN’s work requirement policy is help assisted households advance toward economic self-sufficiency. Specifically, the policy aims to—

 Increase the income of assisted households.

 Increase the number of assisted households with earned income.

 Decrease the number of assisted households paying minimum rent.

Concerns or Needs Considered During Policy Development. Before developing its work requirement policy, INLIVIAN gathered feedback from staff and assisted households through brainstorming sessions, surveys, and community meetings. That effort identified various needs or concerns that were considered during policy development, including lack of access to childcare, lack of transportation, low educational achievement, and lack of job readiness skills.

A description of the supportive services and resources INLIVIAN provides to assisted households to address those barriers and challenges is detailed later in the case study, in the Implementation of the Work Requirement Policy section.

Entities Involved in the Development of the Policy. INLIVIAN’s work requirement policy was developed by staff in collaboration with the Resident Advisory Council. Staff noted that they also received input from the Homeless Services Network (HSN) of Charlotte-Mecklenburg, a community coalition of approximately 40 organizations that work together to serve the homeless community in the Charlotte-Mecklenburg area.

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3. DESCRIPTION OF THE WORK REQUIREMENT POLICY

INLIVIAN’s work requirement policy is paired with

Target Population (Inclusion/Exclusion Criteria)

rent reform to incentivize assisted households to

increase their income up to $2,500 without a rent

At least one work-able adult at all eligible households

that participate in the HCV or PBV program is subject to

increase. 44 The policy requires at least one work-able

INLIVIAN’s work requirement policy.

adult at all households who participate in the HCV or

PBV programs to work at least 20 hours per week. 45

Exclusion:

 Elderly or disabled households.

Work-able adult is defined as an individual who is

between the ages of 18 and 61 and is neither elderly

nor has a disability. Adults categorized as elderly or

Activities That Count Toward the Work

who have a disability are exempt from the policy.

Requirement

Children younger than age 18, who have not



Paid employment:

graduated high school or received their GED, are

o 20+ hours/week.

required to be enrolled in school full time but are not



Education (GED, 2-year degree, 4-year degree):

subject to the work requirement.

o Full-time enrollment.

o Must be combined with part-time employment

INLIVIAN’s work requirement policy allows for

(15+ hours/week).

approved work-related activities, such as job training,  Job/vocational training:

o Full-time enrollment.

education, and volunteering or community service.

o Allowed for up to 12 months.

However, work-related activities are allowed for up to  Volunteer/community service:

12 months during households’ tenure in assisted

o 8 to 15 hours/week.

housing. In addition, assisted households with

o Allowed for up to 60 days.

members enrolled in GED, associate’s degree, or

bachelor’s degree programs are required to be employed part time for at least 15 hours per week.

Volunteer or community service is allowed for up to 60 days during households’ tenure in assisted housing.

INLIVIAN’s work requirement policy was initially implemented as a pilot program at five public housing sites (Moving Forward sites). In 2017, the policy was expanded to eight additional public housing sites (now converted to PBV sites under RAD) and one Jobs Plus Initiative (JPI)46 site. In 2020, the policy was further expanded to include work-able HCV households.

Policy Changes. INLIVIAN has implemented two major policy changes since the work requirement policy went into effect in 2014. Exhibit B.8 summarizes the key policy changes.

44 As part of MTW Rent Reform program, INLIVIAN implemented a stepped rent structure, known as a banded rent policy, that allows assisted households to pay rent based on 30 percent of the lower range of $2,500 income bands. For example, a household with an adjusted income of $5,000 would fall in the $5,000-to-$7,500 income band, and their rent would be 30 percent of $5,000

(the lower range of the band) instead of $7,500 (the upper range of the band).

45 The 20+ hours-per-week work requirement can be met by a combination of two or more work-able adults in the household—

e.g., the work-able head of household and another work-able adult household member.

46 JPI is a HUD program that encourages PHAs to develop local, job-driven approaches to increase incomes and advance employment outcomes for assisted households. For more information about JPI, see

https://www.hud.gov/program_offices/public_indian_housing/jpi.

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Exhibit B.8. Key Policy Changes Implemented by INLIVIAN

Policy Change

Fiscal

Year

Rationale

1. INLIVIAN changed the requirement for paid employment to

20+ hours/week from the initial work requirement, which was

designed to be rolled out in phases. In phase 1, the work

requirement policy required work-able heads of household to

INLIVIAN found that tracking

work a minimum of 15 hours per week. Any additional

compliance under the original design of

household members had to be employed at least 5 hours per

2018

the work requirement presented a

week. After 1 to 3 years in phase 1, households were expected

significant administrative burden. The

to move into phase 2 of the work requirement, requiring work-

new approach has made compliance

able heads of household to work a minimum of 30 hours per

monitoring simpler for the PHA.

week and any additional household members to be employed

at least 10 hours per week.

2. INLIVIAN changed phase 1 sanctions for noncompliance

After INLIVIAN converted its public

households from an approach in which assisted households

housing units to RAD, the PHA learned

lost 50 percent of their housing subsidy for up to 3 months to

that it could not sanction contracted

an approach in which assisted households’ income is

2018

housing assistance payments.

calculated using the state minimum wage multiplied by the

INLIVIAN therefore changed its policy

number of hours required by the work requirement policy (i.e.,

to imputed income at the state’s

20 hours/week) for up to 3 months.

minimum wage rate multiplied by 20

hours/week.

PHA = public housing authority. RAD = Rental Assistance Demonstration.

Note: Sanctions for noncompliant households are detailed in the next section, Implementation of the Work Requirement Policy.

Suspensions of the Policy and Associated Reasons for Suspension. INLIVIAN suspended its work requirement policy for the first time47 in April 2020 due to the COVID-19 pandemic, and the policy remained suspended as of December 2021. Assisted households were not required to comply with the work requirement policy but continued to be offered supportive services. Staff noted that they were monitoring several in-house administrative metrics to help inform their decision on when to reinstate the work requirement. Those metrics included the local rate of unemployment, school closures and the availability of childcare, and the number of local COVID-19 cases.

47 The work requirement was suspended for the first time since the policy was implemented in 2014. Between 2011 and 2013, the policy had been approved but not implemented due to local economic conditions.

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4. IMPLEMENTATION OF THE WORK REQUIREMENT POLICY

Support Services

Working with local partners, INLIVIAN provides a range

Support Services Provided by INLIVIAN

of support services and resources to help assisted



Life coach and case management services.

households make progress toward economic self-



Workforce development services.

sufficiency. Services are not mandatory; they are voluntary  After-school programs.

but highly encouraged. Support services include the



ParentChild+ program.

following:



Homeownership.



College prep and readiness programs.

 Life Coach and Case Management. INLIVIAN offers



College scholarship program.



Childcare subsidies.

onsite life coach and case management services at all



Transportation services.

its properties. Case managers, known as life coaches,



Youth sports and athletic programs.

work one-on-one with assisted households to help them identify strengths, remove barriers to

employment, and achieve their goals toward self-sufficiency. Services are available to all assisted households subject to the work requirement policy, but priority is given to households with the greatest needs—in particular, households paying minimum rent and those that are noncompliant with the work requirement.

 Workforce Development Services. INLIVIAN works with local community partners (e.g., Charlotte Works [local workforce development board] and other local partner organizations) to offer assisted households a range of workforce development services, including job readiness, career assessment, job search and placement, and job training.

 After-School Programs. INLIVIAN partners with two youth organizations (YWCA Central Carolinas and Above and Beyond Students) to provide afterschool programs and summer activities at three of its properties.

 ParentChild+ Program. INLIVIAN operates the ParentChild+ program, an early childhood education program that prepares 2- and 3-year-old children for school success by increasing language and literacy skills, enhancing social-emotional development, and strengthening the parent-child

relationship. The program is offered free of charge to all assisted households.

 Homeownership, College Prep, Youth Sports, Childcare Subsidies, and Transportation Services.

INLIVIAN staff noted that they provide additional support services, including homeownership

programs, college prep and readiness programs, college scholarship programs, childcare subsidies, transportation services, and youth sports and athletics programs. However, specific information about those services was not available to the study team.

Compliance Monitoring

Process for Monitoring Compliance. INLIVIAN uses a work requirement system to monitor, track, and manage assisted households’ compliance with the work requirement. Compliance monitoring is mostly done by life coaches in coordination with property managers. Life coaches meet with the property managers on a monthly basis to review and discuss assisted households’ compliance with the work requirement. Households who are noncompliant are given a 90-day warning period to meet the work requirement; otherwise, they are subject to phase I sanctions (detailed below).

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Work Requirement Policy Compliance Rate. As noted above, INLIVIAN’s work requirement policy has been suspended since April 2020 due to the COVID-19 pandemic. Before that time, staff reported that the average annual compliance rate for the work requirement was about 50 percent. 48

Sanctions for Noncompliance. Assisted households who are noncompliant with INLIVIAN’s work requirement policy are subject to incremental sanctions. The sanctions are implemented in two phases:

 Phase I Sanctions—The assisted household’s income is calculated using the state minimum wage multiplied by the number of hours in the work requirement (i.e., 20 hours/week) for up to 3

months. If the household remains noncompliant after the 3-month period, sanctions are escalated to phase II sanctions.

 Phase II Sanctions—The assisted households lose 100 percent of their housing subsidy for up to 180 days and are required to pay the established contract rent. If the household remains

noncompliant after the 180-day period, they are recommended for termination and are afforded an informal hearing before final program termination. However, terminations from the program due to noncompliance with the work requirement are very rare. Staff reported that fewer than 10

households have been terminated from the program since the policy went into effect in 2014.

Sanction Waivers. INLIVIAN has sanction waivers, known as temporary suspensions, which allow assisted households with extenuating circumstances (e.g., medical emergencies) that prevent them from engaging in work or work-related activities to be exempted from the work requirement. Temporary suspensions are granted on a case-by-case basis and are reviewed every 90 days.

48 INLIVIAN measures its compliance rate on the basis of the employment rate of work-able assisted households.

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5. CHALLENGES, SUCCESSES, AND LESSONS LEARNED

Challenges Implementing the Work Requirement Policy. INLIVIAN staff reported several challenges in implementing its work requirement, including (1) motivating assisted households with multiple barriers to want to work, including assisted households’ concerns that going to work will cause them to experience a

“benefits cliff” because they will no longer qualify for other public assistance that they need to make ends meet; (2) environmental challenges when the area has limited employment opportunities; and (3) internal program challenges with tracking compliance.

Successes of the Work Requirement Policy. 49

Key Successes of INLIVIAN’s Work

INLIVIAN staff noted that its work requirement policy

Requirement Policy

has been very successful in helping assisted households



Average earned income per household increased.

make progress toward self-sufficiency. Staff have



Percentage of households paying minimum rent

observed an increase in wages, a decrease in the number

decreased.

of assisted households that are paying the minimum



Number of working households increased.

rent, and an increase in the number of working households.

Assessment of the Policy. INLIVIAN assessed the impact of the work requirement policy on assisted households in partnership with a team of researchers from the Center for Urban and Regional Studies at the University of North Carolina at Chapel Hill. The published paper is titled Work Requirements in

Public Housing: Impacts on Tenant Employment and Evictions (Rohe, Webb, and Frescoln, 2015). The research examined the impacts of the work requirement policy in the initial five pilot sites. Key findings include the following:

 In the 2+ years before enforcement—when assisted households were receiving case management but the requirement was not enforced—employment did not increase at the work requirement

sites relative to those in the comparison group that did not receive case management. Following enforcement of the work requirement, however, assisted households’ employment increased

significantly, although the average number of hours worked among employed households did not

increase.

 No evidence indicated that sanctions increased evictions or other forms of negative move-outs, possibly due to INLIVIAN’S emphasis on helping tenants reach compliance instead of adopting a punitive approach.

 More than 80 percent of INLIVIAN assisted households responding to the study—including those affected by the policy and those not subject to it—expressed general support for work

requirements. This response suggests that most public housing assisted households have the same values concerning work as the larger population.

Lessons Learned During Implementation and Monitoring of the Work Requirement Policy. INLIVIAN

staff noted that if they could make a change to their current work requirement policy, they might consider a technical change, such as allowing enrollment in a degree program to count toward fulfilling the work requirement for longer than the current 12 months. They acknowledged that continuing schooling and simultaneously working enough hours to comply with the work requirement is difficult, particularly if one has other obligations, such as caring for children. Because additional schooling typically results in increased earning power, this change would likely be beneficial for assisted households.

49 The study team did not have access to the data on successes detailed in this section.

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Staff also noted the importance of having

supportive services in place for the program to be

A work requirement is not for everyone, and it

likely won’t work in every jurisdiction. If you do

successful. As one staff person noted, “It is hard to

not roll it out thoughtfully, you’re setting the PHA

push people into work without providing necessary

up for failure. You have to be realistic about

services.” Finally, staff noted that assessing the

expectations, and carefully consider the local

local job market is critical before launching a new

jurisdiction.

policy such as the work requirement. For example,

—INLIVIAN Staff Member

knowing the local unemployment rate and the types

of jobs that are available enable PHAs to better

tailor services to support assisted households in the pursuit of paid work to fulfill the work requirement.

Overall, INLIVIAN staff believed that the work requirement has been very successful, as demonstrated by many households increasing their wages and a reduction in the number of households paying the minimum rent. Staff believe that the range of supportive services provided by INLIVIAN and a broad set of community partners have been important elements of the program’s success.

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Chicago Housing Authority

1. BRIEF BACKGROUND

The Chicago Housing Authority (CHA) is a public

All work-able adults who are residents of public

housing agency (PHA) based in Chicago, Illinois. 50

housing units or the RAD conversion units are

CHA joined the U.S. Department of Housing and

subject to CHA’s work requirement policy.

Urban Development’s (HUD’s) Moving to Work

(MTW) Demonstration Program51 in 2000 and instituted its work requirement policy in 2009. The goal of CHA’s work requirement policy is to promote economic independence and help assisted households move out of public housing and into mixed-income housing.

CHA’s work requirement policy requires all “work-able adults” who are residents of public housing units or the Rental Assistance Demonstration (RAD)52 conversion units to engage in employment or employment-related activities for at least 20 hours per week. 53 Work-able adults is defined as individuals who are between the ages of 18 and 54 years and are neither elderly nor have a disability. 54 Assisted households in the Housing Choice Voucher (HCV) program are exempt from the policy. 55 Adults categorized as elderly or who have a disability are also exempt from this policy. In addition, CHA has a Safe Harbor provision that allows certain categories of adults to receive temporary exemption from the work requirement—for example, parents of children younger than the age of 1 year, victims of domestic violence, individuals with a temporary medical condition, and those waiting for Supplemental Security Income (SSI) eligibility determination. 56 Details about the policy are discussed in Section 3. Description of the Work Requirement Policy.

In Fiscal Year (FY) 2020, CHA served approximately 65,000 households and had about 143,000

households on its public housing, project-based voucher (PBV), and HCV waiting lists (CHA, 2021).

Staff reported that, as of December 2021, about 5,900 households were subject to the work requirement.

This case study details CHA’s work requirement policy as of December 2021, including the development and implementation of the policy, challenges, successes, and lessons learned. The study team collected the information summarized through interviews with CHA staff and a review of PHA documents, such as annual reports, MTW plans, and other related documents and websites.

50 For more information about CHA, see https://www.thecha.org.

51 MTW, launched in 1996, is a HUD demonstration program that provides PHAs with the flexibility to design and test innovative local strategies. For more information about MTW, see https://www.hud.gov/mtw.

52 RAD is a HUD program that allows PHAs to convert public housing properties to PBV. For more information about the RAD

program, see https://www.hud.gov/RAD.

53 The policy also applies to assisted households in select special programs, for example, CHA’s Re-Entry Pilot Program.

54 Individuals who are 17 years old and not enrolled in school full time are also subject to CHA’s work requirement policy.

55 Staff stated that assisted households in the HCV program are exempt due to difficulties in tracking and monitoring compliance for those households.

56 Assisted households who have lost employment or who are having difficulties obtaining employment can also request Safe Harbor exemption, but CHA requires them to participate in support services if approved. Assisted households who receive Safe Harbor exemption for other reasons are not required to participate in support services.

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2. DEVELOPMENT OF THE WORK REQUIREMENT POLICY

Motivation for Instituting the Policy. CHA instituted its work requirement policy in 2009. Staff reported that they were motivated to implement a work requirement policy as part of a broader Plan for Transformation, through which a CHA redeveloped a portion of its public housing portfolio into mixed-income housing (CHA, 2000). The goal of CHA’s Plan for Transformation was to—

 Rehabilitate or redevelop 25,000 housing units in Chicago.

 Reintegrate low-income families and housing into the larger physical, social, and economic fabric of the city.

 Provide opportunities and services to help residents improve their lives.

 Spur the revitalization of communities once dominated by CHA developments.

Staff noted that CHA wanted to prepare assisted households living in public housing to move into the rehabilitated or redeveloped mixed-income housing.

Desired Policy Outcomes. The goal of CHA’s work requirement policy is to help assisted households achieve economic independence. Specifically, the policy aims to—

 Increase the incomes of assisted households.

 Increase the number of households employed.

Concerns or Needs Considered During Policy Development. As CHA worked to convert its public housing inventory to mixed-income housing, staff determined that some public housing tenants would have difficulty meeting the tenant selection requirement for a mixed-income unit (30 hours of work per week). CHA was concerned that this requirement would relegate tenants to public housing long term and they would not be able to take advantage of the opportunity that mixed-income housing presented. As a result, CHA introduced the work requirement as a step toward preparing the tenants to be eligible for mixed-income units in the future.

Staff reported that CHA also designed the policy to address the stigma associated with those who lived in public housing by providing support services and encouraging potential employers to “take a chance” on public housing tenants.

Staff noted that CHA considered several other needs during policy development, including whether the policy could make a positive difference in families’ lives or increase labor participation rates.

Entities Involved in the Development of the Policy. CHA staff were the primary parties involved in the development of the work requirement policy. CHA’s Department of Resident Services drove the policy development. Staff noted that resident leadership was also involved in the policy development process. In addition, outside advocacy groups provided input during the public comment period. Some groups were supportive of the policy, whereas others believed that the work requirement would result in the eviction of many assisted households.

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3. DESCRIPTION OF THE WORK REQUIREMENT POLICY

CHA’s work requirement policy requires all work-

Target Population (Inclusion/Exclusion Criteria)

able adults who are residents of public housing units

Inclusion—

or RAD conversion units to engage in work at least 20 All work-able adults in—

hours per week. The policy also applies to assisted



Public housing units.

households in select special programs, such as CHA’s  RAD conversion units.

Re-Entry Pilot Program. Work-able adults are defined  Select special programs—e.g., CHA’s Re-Entry as individuals who are between the ages of 18 and 54

Pilot Program.

Exclusion—

years and are neither elderly nor have a disability.



Elderly people and disabled households.

Individuals who are 17 years old and not enrolled in

 Assisted households in the HCV program.

school full time are also subject to the policy.

 Assisted households with a Safe Harbor exemption.

Assisted households in the HCV program are exempt from the policy because, as staff noted, tracking and monitoring compliance for those households is difficult.

The policy includes a Safe Harbor provision, which

Activities That Count Toward the Work

provides a temporary exemption (up to 180 days) for

Requirement

certain categories of adults—for example, parents of



Paid employment—

children younger than the age of 1 year, victims of

o 20+ hours/week.

domestic violence, and individuals with a temporary



Education/training—

medical condition. Assisted households who have lost

o Full-time enrollment.

o Combination of part-time education/training

employment or who are having difficulties finding

and part-time employment.

employment can also request a Safe Harbor



Volunteer/community service—

exemption. However, CHA requires those households

o Up to 10 hours/week.

to participate in support services if approved (details

o Must be combined with part-time employment

or part-time education/training (10+

about support services appear in Section 4.

hours/week).

Implementation of the Work Requirement). Assisted

households who receive Safe Harbor exemption for other reasons are not required to participate in support services. All assisted households with a Safe Harbor exemption are reexamined every 180 days to determine compliance with the conditions of the exemption. At each reexamination, CHA either extends the exemption for another 180 days or denies it. Assisted households who are denied Safe Harbor exemption can appeal the decision through CHA’s grievance process. 57

CHA’s work requirement policy allows for education, job training, or a combination to meet the work requirement. Assisted households are required to be enrolled part time58 or full time in an accredited educational institution or a training program. Assisted households are also allowed to engage in a combination of part-time education or training and part-time paid employment. In addition, households are allowed to participate in volunteer or community service for up to 10 hours per week, but those hours must be combined with part-time education or training or part-time paid employment. 59

57 The grievance process is outlined in CHA’s Resident’s Grievance Procedure. For more information, see https://cha-

assets.s3.us-east-2.amazonaws.com/s3fs-public/2021-03/cha_grievance_procedure_for_rad_program.pdf.

58 Assisted households enrolled part time in an educational institution must meet the remaining work hours requirement through employment or volunteering.

59 Part-time education or training or part-time paid employment must be for at least 10 hours per week.

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Policy Changes. CHA has implemented policy changes since the work requirement policy went into effect in 2009. Exhibit B.9 summarizes the key policy changes.

Exhibit B.9. Key Policy Changes Implemented by CHA

Policy Change

Fiscal Year Rationale

3. CHA changed the target population from “all work-

able public housing residents between the ages of 18

CHA had reduced the number of aged

and 62” to “all work-able public housing residents

2011

properties; therefore, the PHA wanted to keep

between the ages of 18 and 54, and age 17 if not in

the policy focused on work-able families

school full time.”

rather than seniors.

4. CHA began requiring mandatory participation in

support services for all assisted households who

CHA’s resident leadership requested this

receive Safe Harbor exemption because of failure to

change to ensure that households were

obtain employment. This requirement does not apply

2016

compliant and received assistance in meeting

to assisted households who receive Safe Harbor

the requirement at the front end rather than on

exemption for other reasons—e.g., domestic

the back end for a lease violation if

violence or waiting on SSI determination.

noncompliant.

5. CHA expanded the target population for the work

requirement to include residents of RAD conversion

2016

CHA made this change to ensure consistency

properties.

between public housing and RAD properties.

CHA determined that 90 days was insufficient

time for assisted households to establish an

action plan to become compliant with the

6. CHA increased the Safe Harbor period from 90 days

policy, which often resulted in multiple Safe

to 180 days.

2018

Harbor requests. Increasing the time period to

180 days enabled assisted households to work

with a service provider to create and

implement an action and engagement plan.

CHA = Chicago Housing Authority. PHA = public housing authority. RAD = Rental Assistance Demonstration. SSI =

Supplemental Security Income.

Suspensions of the Policy and Associated Reasons for Suspension. CHA has implemented no formal suspensions to its work requirement policy since its inception in 2009, including during the COVID-19

pandemic. However, staff noted that they understood that during the pandemic, more assisted households might enter Safe Harbor status as people lost jobs or left jobs for safety reasons. Staff reported a 10-percent drop in employment during the pandemic but indicated that employment rates among eligible households were beginning to recover as the number of households in Safe Harbor returned to

prepandemic levels.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

4. IMPLEMENTATION OF THE WORK REQUIREMENT POLICY

CHA implemented its work requirement policy immediately upon approval in 2009. However, CHA

provided training to residents before the rollout of the work requirement policy. CHA staff noted that trainings have been in place since 2005 for assisted households moving to mixed-income properties, so CHA was able to add the details of the work requirement policy to those trainings. CHA’s Department of Resident Services contracts with service providers who work with third-party property management firms (also contracted by CHA) to help implement the work requirement policy on the ground.

Support Services

Working with local social service agencies (see exhibit

Support Services Provided by CHA and Its

B.10) to implement its FamilyWorks60 program, CHA

Community Partners

provides a range of resources and support services



Family coaching.

designed to aid assisted households in fulfilling the work



Case management.

requirement, including coaching and access to workforce



Workforce development.

development programs. CHA’s goal in providing services



Financial inclusion.



Digital inclusion.

is to engage a greater number of residents in employment,



Afterschool programs.

education, job training, or community service to achieve



Clinical services and referrals.

economic independence. CHA’s support services include



Support for basic needs.

the following:

 Family Coaching. FamilyWorks offers family coaching services to assisted households. The purpose of these services is to help families navigate and engage with a range of resources, such as— o The community college system (to attend city colleges for no cost through financial aid).

o Partnerships with the local workforce investment boards (which enables assisted

households to be served through the American Jobs Centers).

o Referrals to help families overcome barriers to work (for example, transportation or

childcare).

 Case Management. Case management is a component of family coaching. FamilyWorks providers provide mandatory case management services to assisted households who are granted

Safe Harbor exemption due to challenges obtaining or maintaining employment. This requirement ensures that assisted households receive the necessary support services to become compliant with the work requirement. Case managers work with assisted households to develop an action plan

upon the initial Safe Harbor exemption request and any subsequent requests for an extension to the exemption. The action plan outlines the assisted household’s goals and support services

needed.

 Workforce Development. FamilyWorks providers offer a variety of workforce development readiness services, such as—

o Job Training: Providers operate a job training program known as Transitional Jobs, in which assisted households are paid while learning skills needed for work.

60 CHA offers support services through a service model known as FamilyWorks (details about the FamilyWorks model were not available to the study team). The services are provided by contracted community partners known as FamilyWorks providers.

Assisted households are assigned to specific providers on the basis of their ZIP Code.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

o Job Readiness: Providers offer assisted households various job readiness services,

including resume preparation, interviewing techniques, job search strategies, and career

assessment.

o Referral for Job Search and Placement: Assisted households are referred to CHA’s

contracted workforce development providers for job search and placement services.

 Financial Inclusion. FamilyWorks providers offer opportunities for financial education and resources on topics such as budgeting, personal finances, and homeownership.

 Digital Inclusion. CHA’s Digital Inclusion Services (DIS) program and Digital Resource Centers (DRCs) provide assisted households with access to training services and digital devices.

o DIS Program: DIS offers assisted households various computer trainings, including

Introduction to Computers, Microsoft Word, Computing with Confidence, Recognizing

Internet Scams, Online Security Protection, Utilizing Mobile Applications, and Creating

Google Accounts. DIS also partners with community partners such as Chicago City of

Learning, EveryoneOn, Chicago Public Libraries, Chicago Public Schools, and Chicago

Cook Workforce Partnership to bridge digital divide for specific categories of assisted

households (e.g., youth, seniors, and non-English speakers) through customized computer

trainings and free or low-cost high-speed internet services.

o DRCs: FamilyWorks providers operate nine DRCs in various CHA public housing sites.

The DRCs are equipped with computers, updated software, and projectors and are Wi-Fi

accessible. Onsite staff at the centers provide technical support and programming to help

assisted households use computers. Assisted households can use computers at the centers

to search for jobs and engage in educational activities.

 Afterschool Programs. FamilyWorks providers offer assisted households a variety of youth programming and referrals to youth services. The providers also operate a Summer Youth

Employment Program that connects youth ages 16 to 24 years to meaningful work experiences.

 Clinical Services and Referrals. FamilyWorks providers have licensed clinicians who offer a variety of wellness and mental health services, such as health screenings, counseling, health awareness workshops, and medical referrals.

 Support for Basic Needs. FamilyWorks providers help assisted households address various basic needs, including childcare, utilities, transportation, and health care. Some services are provided through referrals to other organizations.

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Exhibit B.10. Selected CHA Implementation Partners

Name of Partner

Type of Organization

Supportive Services Provided

Job readiness, job training, job

1. Employment and Employer

search and placement, career

Services

Social services provider

counseling, family coaching,

and referrals for social services

Early childhood education,

2. Centers for New Horizons

Social services provider

youth development, workforce

and economic development, and

adult and family services

Early childhood education,

3. Metropolitan Family

parenting resources, and

Services

Social services provider

economic stability

education/counseling

Case management, financial

literacy, economic

4. Near West Side Community

empowerment, homeownership

Development Corporation

Social services provider

education, youth programming,

counseling, education, and

medical referrals

Childcare assistance, parenting

resources, one-on-one coaching,

5. YWCA Metropolitan

career placement, computer

Chicago

Social services provider

training, financial counseling,

mental health, and youth

programming

Compliance Monitoring

Process for Monitoring Compliance. CHA’s FamilyWorks providers and property managers work together to assess and monitor compliance with the work requirement. Providers and property managers at each of CHA’s public housing sites hold monthly coordination meetings where they discuss and address compliance issues. The providers also work with CHA’s Departments of Resident Services and Property & Asset Management to document and track data collected from assisted households. Data tracked include the reason for requesting a Safe Harbor exemption and the timeframe for tracking the 180

days. CHA then pulls the data every 180 days to determine assisted households’ compliance with the work requirement. Noncompliant households can request Safe Harbor exemption but must participate in mandatory support services if approved. Assisted households who refuse to participate in support services are subject to lease termination and eviction. However, staff noted that CHA has never evicted any household due to noncompliance with the work requirement policy.

Work Requirement Policy Compliance Rate. CHA staff reported the average annual compliance rate for their work requirement policy was between 92 and 96 percent. The compliance rate includes assisted 80

A Review of Work Requirement Policies in HUD-Funded Assisted Housing

households who are compliant, 61 those who are exempt, 62 and those in Safe Harbor. In 2021, for example, staff reported a 92-percent compliance rate—i.e., 53 percent of households subject to the work requirement were considered compliant, 13 percent were exempt, and 26 percent were in Safe Harbor.

CHA reported 6 percent of households subject to the work requirement as noncompliant and the rest (2

percent) were under legal review. 63

Sanctions for Noncompliance. As noted above, noncompliant assisted households are subject to lease termination and eviction. However, CHA has never evicted any household for noncompliance with the work requirement since the policy went into effect in 2009.

Sanction Waivers. As noted above, assisted households who are subject to the work requirement can obtain a Safe Harbor exemption for a variety of reasons and can have their exemption recertified an unlimited number of times if their service provider signs off on the request.

61 This category includes assisted households who are employed, participating in education or training, or engaging in volunteer or community service.

62 This category includes assisted households who are categorized as elderly (55+ years old) or have a disability.

63 This category includes assisted households undergoing an eviction proceeding (whether for noncompliance with the work requirement or for other reasons). They are not included in the category of households defined as noncompliant—i.e., households who are not meeting the work requirement and are not approved for a Safe Harbor exemption.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

5. CHALLENGES, SUCCESSES, AND LESSONS LEARNED

Challenges Implementing the Work Requirement Policy. Staff reported that they have experienced some challenges monitoring and tracking assisted households’ compliance with the work requirement. They explained that consistently tracking assisted households’ compliance was a challenge due to difficulty in getting every PHA staff member to understand the importance of monitoring and tracking. To address that challenge, CHA has developed a new data dashboard module that will make monitoring and tracking compliance with the policy easier for property managers.

Successes of the Work Requirement Policy. 64 CHA staff believed that their work requirement policy has been

Key Successes of CHA’s Work Requirement

successful in encouraging assisted households to work.

Policies

They noted that they have experienced positive trends in



Increases in employment, workforce

workforce engagement and retention and increased wages

engagement, and retention.



Secondary benefits for youth school

over the years. Staff also noted that evidence has shown

attendance.

that youth have higher attendance rates at school when the

head of household is employed.

Assessment of the Policy. CHA staff reported that they assess the effectiveness of the work requirement policy internally by measuring employment engagement, tracking year-over-year earnings to determine if assisted households are moving along with the Area Median Income trajectory, and monitoring

noncompliance. Staff also reported that they worked with a local research center at the start of the program to assess the implementation of the policy. The study did not provide feedback on the actual policy, but the focus group and interview findings provided useful information on weaknesses within the program (for example, property management staff not understanding and following the policy) that CHA was able to address.

Lessons Learned During Implementation and

Monitoring of the Work Requirement Policy. CHA

You need a lot of buy-in upfront from residents,

workforce staff, and property management so that

staff highlighted the importance of obtaining buy-in

everyone knows why this is a good thing.

on the value of the work requirement from all

stakeholders, including assisted households,

—CHA Staff Member

property managers, and service providers. They also

emphasized the critical role of supportive services, noting that without supports, many residents would struggle to meet the work requirement. Staff also noted the importance of having supports in place before implementing the policy so assisted households are aware that help is available before they are obliged to comply with the work requirement. In addition, staff underscored that having a work requirement establishes that public housing is temporary while people get back on their feet.

Overall, CHA staff reported a positive experience with the implementation of the work requirement and believed that it has promoted movement of assisted households from public housing to mixed-income housing. CHA staff further noted that the supportive services provided by CHA staff and its partners have been critical to the program’s success.

64 The study team did not have access to the data on successes detailed in this section.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Delaware State Housing Authority

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

1. BRIEF BACKGROUND

The Delaware State Housing Authority (DSHA) is a

All work-able adults in public housing and

public housing agency (PHA) in Delaware that

Housing Choice Voucher (HCV) programs are

serves Kent and Sussex counties. 65 DSHA joined the

subject to DSHA’s work requirement policy and

U.S. Department of Housing and Urban

7-year time limits.

Development’s (HUD’s) Moving to Work (MTW)

Demonstration Program66 in 1999 and instituted its work requirement policy the same year. The ultimate goal of DSHA’s work requirement policy is to help households become economically self-sufficient, allowing them to move out of assisted housing.

DSHA’s work requirement policy is structured as a two-tier system paired with time limits and organized by time in the program: MTW Tier I participants are within their first 5 years in the program, and MTW

Tier II participants are in their sixth and seventh years (final 2 years) of participation in the program (details about the policy are provided in Section 3. Description of the Work Requirement Policy). All work-able adults— defined as individuals who are between the ages of 18 and 57 and are neither elderly nor have a disability—in public housing and HCV programs are subject to the work requirement and the 7-year time limit. Adults categorized as elderly or who have a disability are exempt from this policy.

DSHA serves approximately 1,400 households in any given year, with a goal to serve 500 of those households through its work requirement program, known as the MTW program (DSHA, 2020).

However, as of November 2021, DSHA had only assisted approximately 420 households participating in the program. 67 Staff explained that the number of assisted households in the MTW program fluctuates from year to year due to waiting list cycles that result in increases and decreases in the number of elderly and disabled households served by DSHA. More than 17,000 households are currently on DSHA’s public housing and HCV waiting lists (DSHA, 2020).

This case study details DSHA’s work requirement policy as of November 2021, including development and implementation of the policy, challenges, successes, and lessons learned. The information summarized was collected through interviews with DSHA staff and a review of PHA documents, such as annual reports, MTW plans, and other related documents and websites.

65 For more information about DSHA, see: http://www.destatehousing.com/.

66 MTW, launched in 1996, is a HUD demonstration program that provides PHAs with the flexibility to design and test innovative local strategies. For more information about MTW, see https://www.hud.gov/mtw.

67 That number is the number of assisted households that are subject to DSHA’s work requirement policy and 7-year time limit.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

2. DEVELOPMENT OF THE WORK REQUIREMENT POLICY

Motivation for Instituting the Policy. DSHA instituted its work requirement policy in 1999 as part of the welfare reforms of the 1990s. Staff explained that the state-level leadership at the time wanted to mirror some elements (specifically, the work requirement) of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 in the assisted housing program.

Desired Policy Outcomes. DSHA has three broad goals for its MTW program (DSHA, 2020): 1. Reduce public housing and HCV program costs and achieve cost effectiveness through

administrative reforms such as increasing assisted households’ share of rent to 35 percent of adjusted gross income, time-limiting housing assistance, helping assisted households remove

barriers to self-sufficiency, helping assisted households increase their earned income, and

prohibiting alternative housing subsidies68 while households are receiving housing assistance.

2. Incentivize assisted households to seek employment through initiatives such as amending the waiting list to include a preference for working families, capping rent increases to 35 percent of adjusted gross income, 69 and providing supportive services to assisted households.

3. Increase housing choice for assisted households through services and resources such as financial literacy and counseling, MTW saving accounts, and homeownership education and assistance.

Concerns or Needs Considered During Policy Development. The ultimate goal of DSHA’s work requirement policy is to help households become self-sufficient so that they move out of assisted housing.

Hence, when DSHA developed its work requirement policy, the following concerns or needs of assisted households were considered:

 Poor credit history—Staff noted that most of their assisted households (about 60 to 65 percent) reported that poor credit history was a barrier to self-sufficiency.

 Transportation—Staff noted that parts of Kent and Sussex counties where the PHA operates are rural and lack public transportation. Thus, for households without a car, getting to work is a challenge.

 Childcare—Staff also noted that many of their assisted households reported that lack of access to childcare was a significant barrier to self-sufficiency.

 Seasonal employment—Staff noted that parts of the counties served by the PHA are beach towns that rely on tourism, in which many jobs are seasonal. Members of assisted households in these areas often lose work hours or jobs in the winter months.

Supportive services and resources that DSHA provides to assisted households to address those barriers and challenges are detailed later in the case study, in the Implementation of the Work Requirement Policy section.

Entities Involved in the Development of the Policy. Staff reported that the work requirement policy was developed by DSHA’s leadership at the time, in collaboration with local housing advocacy groups.

68 This rule means that assisted households cannot receive additional housing subsidies while in DSHA’s MTW program. For example, assisted households cannot receive the State of Delaware housing subsidy and the federal MTW subsidy at the same time.

69 Details on how DSHA caps rent increases to 35 percent of adjusted gross income is provided in Section 4. Implementation of the Work Requirement Policy.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

3. DESCRIPTION OF THE WORK REQUIREMENT POLICY

DSHA’s work requirement policy is paired with time

Target Population (Inclusion/Exclusion Criteria)

limits and structured as a two-tier system. All work-



All work-able adults in assisted households are part

able adults in assisted households (referred to as

of DSHA’s MTW program and subject to the work

MTW participants) are automatically enrolled in the

requirement policy and 7-year time limit.

 Elderly and disabled households are excluded.

MTW program and are subject to the work

requirement and 7-year time limits. The policy applies to work-able assisted households in both the public housing and HCV programs.

Under MTW Tier I, defined as the first 5 years of

Activities That Count Toward the Work

participation in DSHA’s MTW program, MTW

Requirement

participants are required to work an incremental



Paid employment:

number of hours: at least 20 hours/week during the

o 20+ hours/week for years 1–2.

first 2 years in the program, at least 25 hours/week in

o 25+ hours/week for year 3.

o 30+ hours/week for years 4–7.

the third year, and at least 30 hours/week in the fourth  Education/training:

and fifth years of participation. At the end of year 5,

o Full-time enrollment.

MTW participants are expected to successfully

o Combination of part-time

complete the program and move out of housing

education/training and part-time

employment.

assistance. MTW participants who are unable to

o Only allowed in years 1–3.

successfully complete the program within 5 years are

enrolled in DSHA’s MTW Tier II. Under MTW Tier II, defined as the final 2 years of participation in DSHA’s MTW program, participants are required to continue working at least 30 hours/week, earning no less than minimum wage. At the end of year 7 of the program, MTW participants are expected to move out of subsidized housing. MTW participants with extenuating circumstances may be granted a short-term extension of housing assistance on a case-by-case basis beyond the 7-year period (DSHA, 2020).

DSHA’s work requirement policy allows for education, job training, or a combination of the two to meet the work requirement during the first 3 years of MTW program participation. MTW program participants are required to be enrolled full time in an educational or training program. They can also engage in a combination of part-time education or training and part-time employment. At the end of year 3, MTW

participants may continue with their education or training; however, they will also be required to work at least 30 hours per week. DSHA staff explained that education or training does not count toward the work requirement beyond year 3 because the goal is to promote self-sufficiency, which, in turn, enables MTW

participants to exit assisted housing.

Policy Changes. DSHA has implemented policy changes since the work requirement policy went into effect in 1999. Exhibit B.11 summarizes the key policy changes.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Exhibit B.11. Key Policy Changes Implemented by DSHA

Policy Change

Fiscal

Year

Rationale

1. DSHA created a time-limited safety-net program, which

allowed MTW participants who were unable to successfully

DSHA wanted to promote self-

complete the MTW program within 5 years (MTW Tier I) to

sufficiency while continuing to provide

continue to receive housing assistance. MTW participants in

2005

needed housing assistance to MTW

the safety-net program were required to continue to work at

participants who were unable to

least 20 hours/week or be enrolled in a full-time educational or

successfully complete the MTW

training program.

program within 5 years.

2. DSHA changed the requirement for paid employment from

DSHA noticed that MTW participants

20+ hours/week to 25+ hours/week in year 3 and 30+

2008

often achieved the 20 hours/week work

hours/week in years 4 to 7.

requirement but did not go beyond that

requirement.

DSHA sought to increase MTW

participants’ self-sufficiency and

eventual exit from housing assistance

3. DSHA eliminated the safety-net program and replaced it with

but realized that the safety-net program

MTW Tier II.

2012

created a false sense of security for

many assisted households: at the time,

120 of 500 households in the MTW

program were in the safety-net

program.

DSHA = Delaware State Housing Authority. MTW = Moving to Work.

Suspensions of the Policy and Associated Reasons for Suspension. DSHA suspended its work requirement policy for the first time since its inception in March of 2020, when the Governor declared a state of emergency due to the COVID-19 pandemic. As a result, DSHA “froze” in time the status of all MTW participants. DSHA reinstated the policy on November 30, 2021, and provided the MTW

participants with 6 months added to their individual time limit. DSHA’s decision to reinstate the work requirement policy depended on the following factors:

 The Governor of Delaware lifting the COVID-19 state of emergency.

 The Centers for Disease Control and Prevention lifting the nationwide housing eviction

moratorium.

 The local unemployment rate declining to its prepandemic level.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

4. IMPLEMENTATION OF THE WORK REQUIREMENT POLICY

Support Services

Working with local partners listed in exhibit B.12, DSHA

Support Services Provided by DSHA and

provides a range of supportive services and resources to

its Community Partners

help MTW participants achieve economic self-sufficiency.



Case management.



Employment services.

Staff noted that supportive services are designed to help



Financial literacy.

address barriers and challenges faced by assisted



MTW savings account.

households. Supportive services include the following:



Adult education services.



Childcare and afterschool programs.

 Case Management. All MTW participants are required

to participate in case management throughout their time in the MTW program. DSHA has four onsite case managers who meet with MTW participants at least once each quarter (more frequently, if

needed), and the services provided are based on MTW Tiers.

o MTW Tier I Case Management—At the start of the program, MTW participants are

required to complete a contract of mutual participation and an individualized case plan,

known as a resident action plan, which is designed to identify barriers to self-sufficiency.

Case managers work one-on-one with MTW participants to help address barriers and

challenges, such as a lack of transportation, lack of access to childcare, acquisition of job skills or education, or securing a driver’s license. Case managers also work with MTW

participants on long-term goals (for example, homeownership, credit repair, ability to pay fair market rent) and refer them to DSHA’s financial literacy program.

o MTW Tier II Case Management—During years 6 and 7, case managers focus their effort

on helping MTW participants who are unable to successfully complete the program within 5

years to find housing. MTW participants are also informed that their housing assistance will

terminate at the end of year 7 in the program.

 Employment Services. DSHA partners with the Delaware Department of Labor (DOL) to provide employment services such as resume preparation, job search, interviewing skills, and job training.

Services are provided through DOL’s One-Stop Centers. DSHA case managers work with participants to identify employment or training needs and refer them to the One-Stop Centers for assistance with job placement or training. In addition, all DSHA public housing sites have computer labs with computers that can be used for job searches.

 Financial Literacy. DSHA partners with several organizations to provide various forms of financial education and counseling services to MTW participants. Those organizations include the National Council on Agricultural Life & Labor Fund, Inc. (NCALL), which provides homeownership

education and counseling, and Consumer Credit Counseling Services, which provides budgeting and credit counseling services.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

 MTW Savings Account. DSHA caps rent increases at 35 percent of adjusted gross income for 5

years. 70 DSHA saves any additional amount that would have been paid by an MTW participant in an escrow account known as an MTW Savings Account. MTW participants who exit the program at the

end of year 5 receive 100 percent of the saved funds, whereas those who exit in year 6 or year 7

receive 60 percent and 40 percent of the funds saved, respectively. MTW participants are required to use at least 60 percent of the escrow funds on housing costs, such as rent or down payment on a house.

 Adult Education Services. DSHA partners with local universities, community colleges, and high schools to provide general education, adult basic education, and GED classes. Those institutions also provide job-specific trainings. In addition, DSHA has installed GED tutorial software at various locations in its public housing sites. Those sites also have instructors who provide group instruction to MTW participants studying for a GED.

 Childcare and Afterschool Programs. Two of DSHA’s public housing sites have onsite childcare centers, and MTW participants are given preference on the waiting lists of those facilities. DSHA has also partnered with the University of Delaware to provide programs through 4-H, an afterschool and summer youth development initiative, at two of its public housing sites. 71 In addition, DSHA partners with two local organizations (Even Start and Child, Inc.) to provide parenting classes.

Exhibit B.12. Selected DSHA Implementation Partners

Name of Partner

Type of

Organization

Supportive Services Provided

Employment services, such as resume

1. Delaware Department of Labor

Government agency preparation, job search, interview

skills, job placement, and job training

2. First State Community Action

Economic support

Employment training, afterschool and

Agency

organization

summer food services program

3. Boys & Girls Clubs of Delaware

Youth organization Afterschool program

4. University of Delaware

Educational

Afterschool and summer youth

institution

development initiative

5. Sussex Tech Adult Education

Educational

Adult basic education and GED

institution

classes

Family enrichment, family planning

6. Children and Families First

Social services

provider

and counseling, and parenting

resources

7. Even Start

Social services

Parenting classes for families with

provider

children younger than 8 years old

70 DSHA caps Total Tenant Payment (TTP) for any dwelling unit to the greater of $50, 35 percent of adjusted monthly income, or 10 percent of monthly income. Tenant rent is computed by subtracting the utility allowance for tenant-supplied utilities, if applicable, from TTP. In instances in which the utility allowance exceeds the TTP, the tenant rent is zero. For assisted households whose 35 percent of adjusted monthly income exceeds $120, the TTP is set at the amount calculated. Once DSHA sets the TTP, the amount does not increase unless the assisted household’s utility share is greater, in which case the TTP may increase up to the amount of the utility allowance. Thereafter, if an assisted household’s income increases, the rent is capped at $350, and the remainder, up to 35 percent of the adjusted monthly income, is placed in an MTW Savings Account by DSHA.

71 For more information about the 4-H program, see https://www.udel.edu/academics/colleges/canr/cooperative-

extension/personal-economic-development/4H-youth-development/programs/.

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A Review of Work Requirement Policies in HUD-Funded Assisted Housing

Name of Partner

Type of

Organization

Supportive Services Provided

8. Child, Inc.

Social services

One-on-one case management and

provider

parenting classes

9. Consumer Credit Counseling

Financial literacy

Services

provider

Budgeting and credit counseling

10. NCALL

Housing counseling

provider

Homeownership education

DSHA = Delaware State Housing Authority. NCALL = National Council on Agricultural Life & Labor Fund, Inc.

Compliance Monitoring

Process for Monitoring Compliance. All MTW participants who are employed are required to provide proof that they are complying with the work requirement by presenting pay stubs to their case manager on a quarterly basis. For those without pay stubs, DSHA accepts letters from employers that are printed on company letterhead. MTW participants who lose employment are given 30 days to find a new job; otherwise, they receive a compliance violation warning, known as a compliance strike. DHSA requires MTW participants who are in educational or training programs to provide academic transcripts to prove compliance with the work requirement policy.

Work Requirement Policy Compliance Rate. DSHA staff reported that before COVID-19, the average compliance rate for their work requirement policy was about 97 percent. 72 After COVID-19 was declared a public health emergency and many businesses shut down in the state, staff reported that the compliance rate dropped significantly until it reached 75 percent, its lowest point, in April 2020. 73 The compliance rate has steadily increased since then, and staff reported that it averaged about 95 to 96 percent as of November 2021.

Sanctions for Noncompliance. DSHA has a “three compliance strike” policy, in which MTW participants who accumulate three compliance warning violations lose their housing assistance. However, DSHA staff noted that getting a third strike is a rare occurrence because they do everything possible to work with noncompliant MTW participants to help them avoid getting a third strike. Staff explained that the policy has been in place since 1999, but fewer than 2 percent of MTW participants have ever received a third strike. In addition, MTW participants who receive three strikes have the option to appeal the decision to a hearing officer, who has the authority to rescind the strike if just cause to do so exists.

Sanction Waivers. DSHA also has sanction waivers, known as temporary exemptions, which allow MTW

participants with extenuating circumstances, such as medical emergencies, to be exempted from the work requirement. Temporary exemptions are granted on a case-by-case basis, and MTW participants are required to provide supporting documentation, such as a doctor’s note, in cases of medical emergency.

72 DSHA measures its compliance rate on the basis of the unemployment rate of MTW participants—that is, staff reported that the average unemployment rate for MTW participants, before COVID-19, was 3 percent.

73 DSHA’s work requirement policy was suspended during this period, so MTW participants were not required to comply with the policy. The compliance rate reflects a 25-percent unemployment rate for MTW participants that was reported by DSHA staff for April 2020.

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5. CHALLENGES, SUCCESSES, AND LESSONS LEARNED

Challenges Implementing Work Requirement Policy. Staff did not report any major challenges in implementing the work requirement. The only challenge staff have experienced is with monitoring compliance, when MTW participants who lose employment fail to notify their case managers. However, staff explained that DSHA is a small PHA, and staff in various offices usually work together as a team, so often the public housing manager or the HCV office will notify case managers in those instances.

Successes of the Work Requirement Policy. DSHA staff

Key Successes of DSHA’s Work

noted that the most successful element of their work

Requirement Policy

requirement policy is its effectiveness in helping many

Overall, 1,015 assisted households have

households achieve self-sufficiency. In FY 2020, DSHA

completed the MTW program since 1999.

reported that 1,015 assisted households had successfully



30 percent (305) have gone on to

completed the MTW program since it was instituted in

homeownership.



70 percent (710) pay full rent.

1999, with about 305 (30 percent) of those households

going on to homeownership and 710 households (70

percent) paying full rent (DSHA, 2020). Staff also noted that the program has helped many participants to achieve their academic goals; for example, several participants earned GEDs or completed employment trainings and were successfully placed in employment—or both.

Assessment of the Policy. DSHA has never conducted a third-party evaluation of its work requirement policy. Staff explained that policy assessments are conducted internally.

Lessons Learned During Implementation and Monitoring of the Work Requirement Policy. Staff stated that implementing a work requirement policy requires patience and flexibility. They explained that when they began their work requirement policy, MTW participants were required to work only a minimum of 20 hours per week; however, over time, DSHA realized that they needed to modify the requirement. They changed the requirement to allow time for the desired effect of increasing assisted households’ work effort to be realized. Staff also emphasized the need to engage the affected households when developing a work requirement policy to alleviate distrust.

Overall, DSHA staff expressed pride in their MTW program, especially because more than 1,000 assisted households have been able to achieve self-sufficiency through the program. The wide range of supportive services provided by DSHA and its community partners has been a critical element of the program’s success. The staff continually assess their program and outline potential changes in the PHA’s annual MTW plan.

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Lawrence-Douglas County Housing Authority

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1. BRIEF BACKGROUND

The Lawrence-Douglas County Housing Authority

All work-able adults in public housing and

(LDCHA) is a public housing agency (PHA) in

Housing Choice Voucher (HCV) programs are

Kansas that was created in 2001 through the merger

subject to LDCHA’s work requirement policy.

of the Lawrence Housing Authority and the Douglas

County Housing Authority. 74 LDCHA serves Douglas County, which includes the city of Lawrence, Kansas. LDCHA joined the U.S. Department of Housing and Urban Development’s (HUD’s) Moving to Work (MTW) Demonstration Program75 in 1999 and instituted its work requirement policy the same year.

The goal of LDCHA’s work requirement policy is to help assisted households achieve economic self-sufficiency.

LDCHA’s work requirement requires all work-able adults to work at least 15 hours per week. LDCHA defines work-able adults as public housing residents or HCV program participants who are between the ages of 18 and 61 years and who are neither elderly nor have a disability. For two-adult households with a child age 13 years or younger, they can fulfill the work requirement if one adult works at least 35 hours per week. Adults categorized as elderly or who have a disability are exempt from this policy. Other exemptions include—

 Temporary medical exemption to households in which one adult member has a medical condition that limits or prevents work activities.

 Exemption to households in which one adult member who is receiving Temporary Assistance for Needy Families (TANF) cash assistance has been determined “not mandatory for work” by the

Kansas Department of Children and Families (DCF).

 Discretionary exemptions to (1) adults who are experiencing significant barriers to employment; (2) adults with caregiving responsibilities (e.g., parents of a child with a disability); and (3) adults who are unable to work for religious reasons. 76

Details about the policy are in Section 3. Description of the Work Requirement Policy.

In Fiscal Year (FY) 2020, LDCHA served approximately 1,300 households and had about 600

households77 on its combined public housing and HCV waiting lists (LDCHA, 2021). Staff reported that, as of December 2021, about 400 households (of about 1,300 total households served annually) were subject to the work requirement policy.

This case study details LDCHA’s work requirement policy as of December 2021, including development and implementation of the policy, challenges, successes, and lessons learned. The study team collected the information summarized through interviews with LDCHA’s staff and a review of PHA documents, such as annual reports, MTW plans, and other related documents and websites.

74 For more information about LDCHA, see https://www.ldcha.org/.

75 MTW, launched in 1996, is a HUD demonstration program that provides PHAs with the flexibility to design and test innovative local strategies. For more information about MTW, see https://www.hud.gov/mtw.

76 Staff noted that LDCHA grants discretionary exemptions on a case-by-case basis, but they are rare.

77 LDCHA allows assisted households to sign up on multiple waiting lists (for example, public housing and HCV), so this number may include duplicates.

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2. DEVELOPMENT OF THE WORK REQUIREMENT POLICY

Motivation for Instituting the Policy. LDCHA instituted its work requirement policy in 1999 as part of the welfare reforms of the 1990s. LDCHA designed the policy to mirror the work requirement of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996. Staff noted that LDCHA did not want to subject their assisted households to two different work requirements.

Desired Policy Outcomes. The goal of LDCHA’s work requirement policy is to help assisted households achieve economic self-sufficiency, providing them with a path to move out of assisted housing.

Concerns or Needs Considered During Policy Development. When LDCHA developed its work requirement policy, it considered the following concerns or needs of assisted households:

 Childcare—Staff noted that many of their assisted households reported lack of access to childcare as a significant barrier to self-sufficiency.

 Transportation—Staff noted that some assisted households reported lack of transportation as a barrier to employment.

 Job Readiness—Staff also noted that some of their assisted households lacked skills needed for successful participation in the workforce.

The Implementation of the Work Requirement Policy section describes the supportive services and resources LDCHA provides to assisted households to address those barriers and challenges.

Entities Involved in the Development of the Policy. LDCHA staff, under the leadership of the Executive Director at that time, developed LDCHA’s work requirement policy. Staff reported that development of the policy was an elaborate process that included multiple meetings with assisted households and a public comment period. LDCHA also engaged various advocacy groups, service providers, and industry groups, including the following organizations:

 Advocacy group—

o Tenants to Homeowners (advocacy group for first-time homeowners).

 Service providers—

o East Central Kansas Economic Opportunity Corporation.

o Kansas Department of Social and Rehabilitation Services.

o Jayhawk Chapter of the Society for Human Resource Management.

o Brookcreek Learning Center (local childcare provider).

o Douglas County Community Transportation Coordinating Council.

 Industry group—

o Practitioners Panel of the City of Lawrence (a local housing advisory council).

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3. DESCRIPTION OF THE WORK REQUIREMENT POLICY

LDCHA’s work requirement policy requires all work-

Target Population (Inclusion/Exclusion Criteria)

able adults, defined as individuals who are between

All work-able adults in assisted households are subject to

the ages of 18 and 61 years and do not have a

LDCHA’s work requirement policy.

disability, to work at least 15 hours per week. The

Exclusion:



Households with elderly members or individuals

policy applies to all work-able adults in both the

with disabilities.

public housing and HCV programs. Two-adult



Households receiving TANF cash assistance with a

households with a child age 13 years or younger may

“not mandatory for work” determination by DCF.

meet the work requirement if one adult works at least



Households with a debilitating medical condition.



Households with discretionary exemptions.

35 hours per week. Adults categorized as elderly or

 Households participating in certain special

having a disability are exempt from the policy. Other

programs, such as VASH, HOME, HOPE,

policy exemptions include—

Transitional Vouchers, Mainstream Vouchers, and

Emergency Housing Vouchers.

 Exemption to households receiving TANF

cash assistance with one adult member who has been determined “not mandatory for work” by

DCF.

 Temporary medical exemption to households in which an adult member has a medical condition, certified by a licensed physician, that lasts more than 3 months and limits or prevents work

activities.

 Discretionary exemption to households with

Activities That Count Toward the Work

only one adult who does not have a disability

Requirement

status, or who—due to limitations of



Paid employment—

employment experience, education or training,

o 15+ hours/week.

o For two-adult households with a child age 13 or

or other barriers—is unable to earn sufficient

younger, 35+ hours per week for one adult.

income to meet LDCHA’s minimum MTW



Education/training—

rent requirement. 78 Discretionary exemption

o Full-time enrollment.

may also be granted to assisted households



Volunteer—

with caregiving responsibilities, such as a

o 15+ hours/week.

parent of a child with a disability who is



FSS—

o 15+ hours/week.

needed for the child’s care. In addition,

exemption may be granted to assisted households who are unable to work for religious reasons.

Staff noted that LDCHA grants discretionary exemptions on a case-by-case basis, but they are

rare (less than 0.5 percent annually).

 Exemption to assisted households participating in certain special programs, such as Veterans Affairs Supportive Housing (VASH), Housing Opportunities Made Equal (HOME), Housing

Opportunities and Prevention of Evictions (HOPE) Program, Transitional Vouchers, Mainstream

Vouchers, and Emergency Housing Vouchers.

LDCHA’s work requirement policy allows for education, job training, or a combination of the two to meet the work requirement. Assisted households are required to be enrolled full time in an accredited educational institution or training program. Assisted households are also allowed to engage in volunteer activities to meet the work requirement; they must volunteer at least 15 hours per week. In addition, 78 LDCHA sets its MTW minimum rent requirement on the basis of the size of the housing unit, and the requirement is adjusted periodically. For example, in FY 2020, the minimum rent for one-bedroom and five-bedroom units was $185 and $315, respectively.

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assisted households may meet the work requirement by participating in LDCHA’s Family Self-

Sufficiency (FSS) program or the Resident Opportunities and Self Sufficiency-Service Coordinators (ROSS-SC)79 program for at least 15 hours per week. The program offers education and training opportunities to help assisted households reduce barriers to employment.

Policy Changes. LDCHA has implemented one major policy change since the work requirement policy went into effect in 1999. Exhibit B.13 summarizes the policy change.

Exhibit B.13. Key Policy Change Implemented by LDCHA

Policy Change

FY

Rationale

LDCHA dropped the number of work

Economic downturn made finding and

hours required from 20+ hours/week to

2007

retaining a job difficult for assisted

15+ hours/week.

households.

LDCHA = Lawrence-Douglas County Housing Authority.

Suspensions of the Policy and Associated Reasons for Suspension. In April 2020, LDCHA suspended its work requirement policy for the first time since its inception due to the COVID-19 pandemic. Staff noted that LDCHA only suspended the policy to allow assisted households to qualify for LDCHA’s Hardship Rent Reduction (detailed in the Sanction Waivers section). LDCHA reinstated the policy in March 2021 as part of a broader rollback of measures it had instituted in response to the COVID-19

pandemic.

79 ROSS-SC is a HUD grant program that provides funding to PHAs to hire and maintain service coordinators who assess the needs of assisted households and coordinate community resources to meet those needs. For more information about ROSS-SC, see https://www.hud.gov/program_offices/public_indian_housing/programs/ph/ross/about.

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4. IMPLEMENTATION OF THE WORK REQUIREMENT POLICY

Support Services

Working with local partners (see exhibit B.14), LDCHA

Support Services Provided by LDCHA and

provides a range of supportive services and resources to

Its Community Partners

help assisted households achieve economic self-



Workforce development services.

sufficiency. Staff noted that supportive services are



Transportation services.



Education services.

designed to help address barriers and challenges faced by



Childcare.

assisted households and include the following:



Afterschool program.



Homeownership program.

 Workforce Development Services. LDCHA



Financial literacy.

provides various workforce development services to help assisted households address barriers to employment.

 Job readiness: LDCHA has two full-time employment specialists who provide job readiness services such as resume preparation, job search strategies, interviewing techniques, and

career assessment. LDCHA also has an onsite computer lab with laptops and desktop

computers that participants can use for job searches and resume writing. In addition, LDCHA

uses local grant funding to help assisted households purchase clothing for interviews and

work (e.g., scrubs, nonslip shoes, and steel-toed shoes).

 Job training: LDCHA works with the Lawrence Workforce Center (the local One-Stop

Center) and local universities and community colleges to provide training for jobs such as

medical or nursing assistant, bookkeeper, social worker, electrician. LDCHA staff work with

assisted households to identify and access training opportunities and resources. In addition, staff noted that when funding is available, they help assisted households pay for some courses and certification or licensing exams. LDCHA also offers computer skills training to assisted

households through its onsite computer lab.

 Employment referrals: LDCHA works with local employers and the Lawrence Workforce

Center to refer assisted households for employment opportunities.

 Transportation Services. LDCHA has a car repair program that provides up to $500 to assisted households to repair vehicles used for employment and education purposes. LDCHA also provides bus passes, funding for driver’s education, and funding for a driver’s license to help assisted households address transportation barriers.

 Education Services. LDCHA works with Lawrence Public Schools to provide adult basic education and GED classes. LDCHA staff also provide assisted households interested in further education with services such as researching colleges, applying for federal student aid, and enrolling in college. The agency also offers postsecondary tutoring to help assisted households who are already in school. In addition, LDCHA receives private grants, which can be used to purchase laptops and other devices to enable remote schooling for assisted households.

 Childcare. LDCHA partners with a provider who operates an onsite daycare center at its largest public housing site. Assisted households are given preference on the daycare center’s waiting list.

Staff noted that childcare assistance from DCF has a waiting period, so sometimes LDCHA provides funding to bridge the gap. In addition, LDCHA has an Early Childhood Program that offers assisted 97

A Review of Work Requirement Policies in HUD-Funded Assisted Housing

households who are expecting a child or who have young children, from birth to 6 years of age, with case management services. The program also offers referral services for childcare, parenting

education, early education, and baby supplies (e.g., diapers, formula, and strollers).

 Afterschool Program. LDCHA offers a year-round afterschool program, Full Circle Youth Program, at its largest public housing site. The program, which serves children ages 7 to 17, offers services such as academic tutoring, wellness or fitness activities, arts and crafts, and college prep. The program also provides referral services to partner organizations, including the Boys and Girls Club of Lawrence, VanGo, and the Children’s Shelter.

 Homeownership Program. LDCHA operates a Homeownership Program (HOP) that prepares households to successfully transition from assisted housing to homeownership. LDCHA invites

assisted households who earn at least 50 percent of the Area Median Income to join the program.

HOP offers a savings match of up to $3,000 that households can use toward a down payment for a house or other housing-related expenses.

 Financial Literacy. LDCHA partners with financial literacy providers (Housing and Credit Counseling, Inc. and Consumer Financial Protection Bureau) to provide financial education,

including money management, wealth creation, budgeting, and credit repair.

Exhibit B.14. Selected LDCHA Implementation Partners

Name of Partner

Type of Organization

Supportive Services Provided

1. Lawrence Workforce Center Government agency

Job readiness and training

2. Peaslee Tech

Educational institution

Job training

3. Kansas University

Educational institution

Degree and nondegree courses,

job-specific training

4. Lawrence Public Schools

Educational institution

Adult basic education and GED

classes

5. VanGo

Social services provider

Youth development and job

training programs

6. Children’s Shelter

Social services provider

Foster care

7. Boys and Girls Club of

Lawrence

Youth organization

Afterschool program

8. Housing and Credit

Counseling, Inc.

Financial literacy provider

Financial education

9. Consumer Financial

Protection Bureau

Government agency

Financial education

10. Habitat for Humanity

Nonprofit housing organization Financial education

11. Tenants to Homeowners

Nonprofit housing organization Financial education

12. Catholic Charities

Social services provider

Financial education

13. Growing Food Growing

Health (part of Community

Mercantile Education

Nonprofit nutrition organization Nutrition

Foundation)

14. Kansas State Research and

Extension

Nutrition research organization

Nutrition

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Name of Partner

Type of Organization

Supportive Services Provided

15. SunRise Project

Nonprofit nutrition organization Nutrition and youth programs

16. Human Services Coalition

Social services provider

Financial resources

17. Housing Stabilization

Collaborative

Social services provider

Financial resources

GED = General Educational Development. LDCHA = Lawrence-Douglas County Housing Authority.

Compliance Monitoring

Process for Monitoring Compliance. MTW households are subject to the work requirement at admission or move-in to public housing or HCV programs. LDCHA gives assisted households 30 days to comply with the policy if they are not in compliance at admission. In addition, LDCHA enforces the work requirement at annual recertification and for Hardship Rent Reduction (detailed below). It gives households 14 days to comply with the work requirement at their annual recertification if they are not in compliance with the policy. Staff noted that they do not monitor compliance between annual

recertifications. During annual recertifications, LDCHA requires assisted households to provide proof that they are complying with the work requirement by providing income documentation, such as pay stubs (three are required), tax returns, etc. For assisted households who are in educational or training programs, LDCHA requires academic transcripts to prove compliance with the policy. LDCHA gives assisted households who are not in compliance at annual recertification 14 days to meet the work requirement; otherwise, the household will receive notice of compliance violation.

Work Requirement Policy Compliance Rate. LDCHA staff reported that the compliance rate for their work requirement policy was 100 percent as of December 2021. 80

Sanctions for Noncompliance. Households who are noncompliant are provided the opportunity to participate in the PHA’s FSS or ROSS-SC program to meet their work requirement, but participation is voluntary. The FSS and ROSS-SC programs offer various job readiness or training and education opportunities to help assisted households address barriers to employment. LDCHA sanctions assisted households who remain noncompliant after referral to the FSS or ROSS-SC programs. Possible sanctions include increasing rent to full market rate and termination from housing assistance. However, staff noted that they have never terminated any household for noncompliance with the work requirement.

Sanction Waivers. LDCHA provides a degree of rent relief to assisted households who experience loss of earned income through sanction waivers, known as Hardship Rent Reduction. Rent is reset to $50 per month (up to 3 consecutive months) for households whose loss of income is equal to or greater than 50

percent of their reported earned income. If the loss of income is at least 25 percent but less than 50

percent of total reported earned income, the rent is reset to $100 per month (up to 3 consecutive months).

LDCHA allows households to request rent hardship reduction only once every 12 months. However, it does not allow Hardship Rent Reduction during annual recertification because rent has already been recalculated at that time. LDCHA also does not allow Hardship Rent Reduction when a household has already had one waiver in the previous 12 months or if an unemployed household refuses to participate in the FSS or ROSS-SC programs.

80 LDCHA measures its compliance rate on the basis of the number of assisted households terminated from the work requirement program. Staff reported that they have never terminated or evicted any household for noncompliance with the work requirement since the policy went into effect.

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5. CHALLENGES, SUCCESSES, AND LESSONS LEARNED

Challenges Implementing the Work Requirement Policy. Staff did not report any major challenges in implementing LDCHA’s work requirement. However, staff noted a lack of awareness about the policy in the first year of implementation. Many assisted households were shocked when they were required to recertify compliance at the end of year 1 even though the PHA had mailed them a lot of information about the policy. LDCHA did not sanction those households; instead, they were allowed to recertify the following year. Staff noted that the policy has become well-known by assisted households since the initial year. Staff also reported that the structure of LDCHA’s income deduction system81 is somewhat complicated. Staff explained that the system requires them to track the number of hours worked and associated deductions, which can be burdensome at times.

Successes of the Work Requirement Policy. LDCHA

Key Success of LDCHA’s Work Requirement

staff noted that the most successful element of their

Policy

work requirement policy is that it has helped many



Since 1999, 104 assisted households have become

assisted households achieve self-sufficiency. They

homeowners.



Households have experienced improved career and

reported that 104 households have left assisted

life trajectory.

housing to become homeowners since LDCHA

implemented the policy in 1999. Staff also noted that the policy has transformed the lives of many households; for example, some assisted households have been able to achieve their academic goals and have gone on to establish successful careers as nurses and social workers.

Assessment of the Policy. LDCHA has never conducted a third-party evaluation of its work requirement policy. Staff explained that they conduct policy assessments internally.

Lessons Learned During Implementation and

Monitoring of the Work Requirement Policy. Staff

I would not recommend doing a work requirement

without providing internal employment and education

stated that implementing a work requirement policy

supports through FSS and ROSS-SC. I would be

in jurisdictions similar to LDCHA is feasible;

philosophically opposed to that because I don’t think

however, they emphasized that PHAs must provide

that’s a fair application of a work requirement.

support services internally for the policy to be

—LDCHA Staff Member

successful. They noted that PHAs should provide

support services, beyond housing assistance, that can comprehensively address employment and

education barriers and challenges faced by assisted households.

Overall, LDHCA staff noted that the work requirement policy has been instrumental in helping many assisted households achieve economic self-sufficiency. They credit the success of the policy to the wide array of support services they provide to assisted households.

81 The income deduction system allows LDCHA to provide special income deductions to MTW-assisted households. For example, in FY 2020, LDCHA offered the following special deductions: (1) a 10-percent earned income deduction for households working at least 35 hours per week, (2) a $2,000 medical deduction for assisted households working at least 35

hours per week, (3) a full out-of-pocket dependent care deduction necessary to allow work or school attendance, (4) a utility allowance as an annual income deduction, and (5) an increase in the child dependent deduction to $840 per child up to a maximum of $1,680 per household. The goal of the deduction system is to prevent assisted households from being penalized (through rent increase) for working more hours to increase their income.

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Lexington-Fayette Urban County Housing Authority

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1. BRIEF BACKGROUND

The Lexington-Fayette Urban County Housing

Work-able heads-of-households or co-

Authority (LHA) is a public housing agency (PHA)

heads/spouses in SSI, SSII, and Centre Meadows

in Kentucky that serves the consolidated city-county

housing units are subject to LHA’s work

of Lexington-Fayette. 82 LHA joined the U.S.

requirement policy.

Department of Housing and Urban Development’s

(HUD’s) Moving to Work (MTW) Demonstration Program83 in 2011 and instituted its work requirement policy, known as the Local Self-Sufficiency Admissions and Occupancy Requirement, for Self-Sufficiency Level I (SSI)84 units, Self-Sufficiency Level II (SSII)85 units, and Centre Meadows86 units in 2014. LHA also instituted a pilot work requirement policy, known as Housing Choice Voucher Time Limit Pilot Program, for select Housing Choice Voucher (HCV) program participants in 2018. 87 The goal of LHA’s work requirement policies is to help assisted households make progress toward economic self-sufficiency.

LHA’s Local Self-Sufficiency Admissions and Occupancy Requirement policy requires the following for assisted households in SSI, SSII, and Centre Meadows units:

 SSI—Work-able head of household (HH) or co-head/spouse must work at least 37.5 hours per week, earning no less than the federal minimum wage.

 SSII and Centre Meadows—Work-able HH or co-head/spouse must work at least 20 hours per week, earning no less than the federal minimum wage.

Work-able HH or co-head/spouse is defined as an individual between the ages of 18 and 61 years and is neither elderly nor has a disability. HHs or co-heads/spouses categorized as elderly or who have a disability are exempt from this policy. HH and co-head/spouses who are full-time students are also exempt from the policy.

LHA pairs its Housing Choice Voucher Time Limit Pilot Program with a 5-year time limit organized by time in the program. In the first 2 years in the program, the program requires the HH or co-head/spouse to work at least 20 hours per week, earning no less than the local or federal minimum wage (whichever is higher), at least 25 hours per week in year 3 of participation in the program, and at least 37.5 hours per week in years 4 and 5 and any subsequent years of participation in the program. 88 Section 3. Description of the Work Requirement Policy provides details about LHA’s work requirement policies .

82 For more information about LHA, see https://www.lexha.org/home.

83 MTW, launched in 1996, is a HUD demonstration program that provides PHAs with the flexibility to design and test innovative local strategies. For more information about MTW, see https://www.hud.gov/mtw.

84 SSI are newer or more desirable public housing units that are single-family homes.

85 SSII are newer or more desirable public housing units that are either townhomes or apartments.

86 Centre Meadows is an apartment community that provides project-based voucher (PBV) housing units.

87 LHA’s Housing Choice Voucher Time Limit Pilot Program is a volunteer program. LHA recruited the initial cohort of assisted households from its HCV waiting list. LHA offered households vouchers (regardless of their position on the waiting list) in exchange for enrolling in the Housing Choice Voucher Time Limit Pilot Program. LHA recruited 25 assisted households for the initial cohort of the program. As of December 2021, 18 households remained in the program.

88 LHA allows assisted households who are unable to complete the Housing Choice Voucher Time Limit Pilot Program within 5

years to request a 2-year extension.

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In Fiscal Year (FY) 2019, LHA served approximately 4,000 households and had about 6,700

households89 on its combined public housing and HCV waiting lists (LHA, 2020). Staff reported that, in the same year, 813 households (643 in SSI and SSII, 152 at the Centre Meadows site, and 18 in the HCV

pilot program) were subject to the work requirement policy.

This case study details LHA’s work requirement policy as of December 2021, including development and implementation of the policy, challenges, successes, and lessons learned. The study team collected the information summarized through interviews with LHA staff and a review of PHA documents, such as annual reports, MTW plans, and other related documents and websites.

89 LHA allows assisted households to sign up on multiple waiting lists (for example, public housing and HCV), so this number may include duplicates.

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2. DEVELOPMENT OF THE WORK REQUIREMENT POLICY

Motivation for Instituting the Policies. LHA instituted its Local Self-Sufficiency Admissions and Occupancy Requirement policy in 2014 to encourage assisted households to gain or maintain employment so they can eventually achieve self-sufficiency. LHA also wanted to eliminate loopholes that a small but significant number of assisted households used to avoid work requirements. Staff noted that before implementation of the work requirement, some assisted households had a tendency to quit their jobs after they had moved into public housing so their rent would be reduced. LHA instituted its HCV Time Limit Pilot Program in 2018 to encourage assisted households to make progress toward self-sufficiency.

Desired Policy Outcomes. The goal of LHA’s Local Self-Sufficiency Admissions and Occupancy Requirement policy and Housing Choice Voucher Time Limit Pilot Program is to help assisted

households gain and maintain employment so they can advance toward self-sufficiency. Specifically, the policies aim to accomplish the following:

 Increase the income of assisted households.

 Increase the number of households that are employed.

Concerns or Needs Considered During Policy Development. Staff reported LHA considered transportation and childcare needs of assisted households in the development of both the Local Self-Sufficiency Admissions and Occupancy Requirement policy and the Housing Choice Voucher Time

Limit Pilot Program. They noted that LHA typically refers assisted households to social service agencies for assistance; however, households must meet the work requirement before admission in both programs.

Entities Involved in the Development of the Policies. LHA staff developed the Local Self-Sufficiency Admissions and Occupancy Requirement policy. The PHA also held community meetings known as

MTW Stakeholder Meetings that included assisted households and community partners, such as

Community Action Kentucky, Lexington Fair Housing Council, City of Lexington, and Lexington-

Fayette Urban County Government Department of Social Services. In addition, LHA held public hearings so that the public was aware of the policy. A committee of about five LHA staff members developed the HCV Time Limit Pilot Program.

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3. DESCRIPTION OF THE WORK REQUIREMENT POLICY

LHA’s Local Self-Sufficiency Admissions and

Target Population (Inclusion/Exclusion Criteria)

Occupancy Requirement policy includes the

Work-able HHs or co-heads/spouses in SSI, SSII, and

following requirements for assisted households in

Centre Meadows housing units are subject to LHA’s

SSI, SSII, and Centre Meadows units:

work requirement policy.

Exclusion—

 SSI—Work-able HH or co-head/spouse is



Elderly or disabled households.

 Full-time students.

required to work at least 37.5 hours per week,

earning no less than the federal minimum wage.

 SSII and Centre Meadows—Work-able HH or co-

head/spouse is required to work at least 20 hours

Activities That Count Toward the Work

per week, earning no less than the federal

Requirement

minimum wage.



Unsubsidized employment.



Subsidized private-sector employment.

Work-able HH or co-head/spouse is defined as an



Subsidized public-sector employment.

individual between the ages of 18 and 61 years who is

 Paid on-the-job training.

neither elderly nor has a disability. HHs or co-heads/spouses categorized as elderly or who have a disability are exempt from this policy. HHs and co-heads/spouses who are full-time students are also exempt from the policy.

LHA pairs its Housing Choice Voucher Time Limit Pilot Program with a 5-year time limit organized by time in the program. In the first 2 years in the program, the HH or co-head/spouse is required to work at least 20 hours per week, earning no less than the local or federal minimum wage (whichever is higher), at least 25 hours per week in year 3 of participation in the program, and at least 37.5 hours per week in years 4 and 5 and any subsequent years of participation in the program. Assisted households who are unable to complete the program within 5 years may request an extension of up to 2 years (for a maximum of 7

years). The Housing Choice Voucher Time Limit Pilot Program is very small, with only 18 households participating in the program as of December 2021. 90

LHA’s Local Self-Sufficiency Admissions and Occupancy Requirement policy and Housing Choice

Voucher Time Limit Pilot Program do not allow for education, unpaid job training, or volunteer activities to meet the work requirements. However, the policies allow for paid on-the-job training and subsidized employment. Staff noted that LHA expects assisted households to meet the minimum requirements regardless of the type of work activity.

Policy Changes. LHA has implemented one major change to its Local Self-Sufficiency Admissions and Occupancy Requirement policy since it went into effect in 2014. Exhibit B.15 summarizes the policy change. The PHA has not implemented any policy changes to its Housing Choice Voucher Time Limit Pilot Program since it went into effect in 2018.

90 Staff reported that 7 of the initial 25 households selected to participate in the Housing Choice Voucher Time Limit Pilot Program did not sign a lease.

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Exhibit B.15. Key Policy Change Implemented by LHA

Policy Change

Fiscal

Year

Rationale

LHA reduced the requirement for prospective tenants in SSI and

LHA wanted to increase the number of

SSII to have a prior employment history from 6 consecutive months

2016

prospective tenants eligible for SSI and

to 3 consecutive months.

SSII units.

LHA = Lexington-Fayette Urban County Housing Authority. SSI = Self-Sufficiency Level I. SSII = Self-Sufficiency Level II.

Suspensions of the Policy and Associated Reasons for Suspension. LHA has never suspended its Local Self-Sufficiency Admissions and Occupancy Requirement policy or the Housing Choice Voucher Time Limit Pilot Program since they went into effect in 2014 and 2018, respectively. However, LHA waived sanctions for noncompliant assisted households from April 2020 to December 2021 due to the COVID-19

pandemic. The PHA also waived the 3-month work history requirement for prospective tenants in the SSI and SSII units. Staff stated that the decision to end the waivers was based on HUD’s waiver provisions and state and federal guidance.

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4. IMPLEMENTATION OF THE WORK REQUIREMENT POLICY

Support Services

LHA does not provide support services to assisted households subject to its Local Self-Sufficiency Admissions and Occupancy Requirement policy. It refers households in need of support services to appropriate resources. The PHA does not have staff through the work requirement programs for referral services, so house managers and specialists often fulfill that role. In addition, LHA often refers households in need of support services to its in-house service coordinator or the Resident Opportunities and Self-Sufficiency Service Coordinator to connect the households with support services. Staff noted that they are unable to provide support services due to limited funding.

LHA also does not provide support services to assisted households in the Housing Choice Voucher Time Limit Pilot Program. However, an HCV specialist in the program works one-on-one with assisted households to identify and refer them to appropriate support services.

Compliance Monitoring

Process for Monitoring Compliance. LHA requires assisted households to recertify compliance on an annual basis. During recertification, housing specialists conduct employment verification by obtaining third-party verification directly from employers. LHA also requires assisted households to provide at least six pay stubs for documentation. Households who are not in compliance with the work requirement policies are subject to sanctions.

Work Requirement Policy Compliance Rate. LHA staff reported that, before the COVID-19 pandemic, the average annual compliance rate for the Local Self-Sufficiency Admissions and Occupancy

Requirement policy was about 80 percent. Staff noted that the compliance rate for this program has dropped significantly since the pandemic began. In FY 2020, LHA reported that the compliance rate for the Housing Choice Voucher Time Limit Pilot program was 94 percent.

Sanctions for Noncompliance. Assisted households who are noncompliant with the work requirement policies are subject to the following income imputations, illustrated in exhibit B.16. 91

Exhibit B.16. FY 2019 Annual Income Imputation for LHA

Program

Minimum

Hourly Rate

FY 2019 Imputed Income

Hours

SSI

37.5

Federal minimum wage $7.25 x 37.5 x 52 = $14,138

SSII and Centre

20

Federal minimum wage $7.25 x 20 x 52 = $7,540

Meadows

Sanction Waivers. LHA has sanction waivers known as the Hardship Policy, which allows assisted households that lose employment through no fault of their own to pay minimum rent92 for up to 90 days while they seek to regain employment. The hardship requests can be renewed, and assisted households are not limited in the number of requests allowed.

91 Income imputations for assisted households in the Housing Choice Voucher Time Limit Pilot Program are similar to those in the Local Self-Sufficiency Admissions and Occupancy Requirement policy.

92 In FY 2019, LHA’s minimum rent was $150 per month.

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5. CHALLENGES, SUCCESSES, AND LESSONS LEARNED

Challenges Implementing the Work Requirement Policies. Staff reported three major challenges implementing the work requirement policy, including the following:

1. Limitation on imposing sanctions for noncompliant assisted households. Staff noted that they cannot force assisted households to move out because most do not have any other options for

housing.

2. Staff also noted that many households subject to the policy expressed displeasure with or resistance to complying with the work requirement, which made the policy more challenging to

implement.

3. In addition, staff noted that self-sufficiency was difficult to achieve even when assisted households work full time at minimum wage because the minimum wage is not sufficient for

them to afford basic necessities and the costs associated with employment (e.g., transportation and childcare).

Successes of the Work Requirement Policies. LHA staff

Key Success of LHA’s Work Requirement

reported that the policy has been successful, as over the

Policies

years they have seen assisted households who once received Staff reported that some assisted households have housing assistance buy their own home, pay off debt, go

gone on to purchase their own homes, pay off

back to school, or start their own business. Staff noted that

debt, or start a business.

some assisted households also participated in LHA’s Family Self-Sufficiency programs, and similar successes can be observed through that program.

Assessment of the Work Requirement Policies. LHA has not conducted a third-party evaluation of its work requirement policies. However, the PHA has contracted an independent consultant to conduct an annual assessment of its broader MTW program.

Lessons Learned During Implementation and Monitoring of the Work Requirement Policies. LHA staff identified the following lessons learned from the implementation and monitoring of the work requirement policy:

 Educating residents about the work requirement policy and any changes the PHA chooses to

make to the policy over time is important.

 Having multiple options available for assisted households who may face sanctions for

noncompliance may be helpful.

Overall, LHA staff noted that despite the challenges detailed above, the work requirement policy has motivated a substantial number of assisted households to gain employment and make progress toward economic self-sufficiency.

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Louisville Metro Housing Authority

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1. BRIEF BACKGROUND

The Louisville Metro Housing Authority

(LMHA) is a public housing agency (PHA) that

All work-able adults in new single-family, scattered-

site public housing units were subject to LMHA’s

was formed in 2003 when the Housing Authority

work requirement policy and a 5-year residency time

of Louisville and the Housing Authority of

limit.

Jefferson County merged. 93 LMHA joined the

U.S. Department of Housing and Urban Development’s (HUD’s) Moving to Work (MTW) Demonstration Program94 in 1999 and instituted a work requirement policy in fiscal year (FY) 2007. The ultimate goal of LMHA’s work requirement policy was to incentivize assisted households to work toward self-sufficiency.

The work requirement policy was sunsetted in 2017.

LMHA’s work requirement policy required work-able adults at new single-family, scattered-site public housing units95 to be employed for a minimum of 20 hours per week or be enrolled as a full‐time student in an accredited postsecondary educational institution. The policy was paired with a 5-year residency time limit96 and mandatory participation in case management. 97 Work-able adults were defined as individuals without a disability who were between the ages of 18 and 61. Adults categorized as elderly (that is, 62

years or older) or who had a disability were exempt from the component of the work requirement that mandated paid employment or education, but the households were required to participate in case management. Details about the policy are in Section 3. Description of the Work Requirement Policy .

LMHA eliminated the 5-year residency time limit and the mandatory case management component of the work requirement policy in FY 2016 to increase occupancy at the new single-family, scattered-site public housing units. LMHA eventually ended the entire work requirement policy in FY 2017 because vacancy levels at those properties remained high. Staff stated that because assisted households had the option to lease public housing units that were not subject to the work requirement, the PHA had difficulty leasing the new units subject to the work requirement policy.

LMHA served about 12,600 households in FY 2019, and in that same year, about 17,000 households98

were on the waiting lists (LMHA, 2019). In the year before sunsetting the work requirement policy, 106

households were subject to the work requirement (LMHA, 2016).

This case study details LMHA’s work requirement policy from 2007 through 2017, including the

development and implementation of the policy, challenges, successes, and lessons learned. The information summarized was collected through interviews with LMHA staff and a review of PHA

documents, such as annual reports, MTW plans, and other related documents and websites.

93 For more information LMHA, see https://www.lmha1.org/.

94 MTW, launched in 1996, is a HUD demonstration program that provides PHAs with the flexibility to design and test innovative local strategies. For more information about MTW, see https://www.hud.gov/mtw.

95 New single-family, scattered-site public housing units are detached, single-family rental units that were newly developed by LMHA under HUD’s HOPE VI program. The goal of the HOPE VI program is to help PHAs revitalize distressed properties (for more information, see https://www.hud.gov/program_offices/public_indian_housing/programs/ph/hope6/about).

96 Assisted households making progress toward self-sufficiency were allowed to request a residency extension for up to 2 years, which was granted on a case-by-case basis. Extensions beyond 7 years were not allowed.

97 The case management requirement could be fulfilled by participating in LMHA’s Family Self-Sufficiency program or Individual Development Account program.

98 LMHA allowed assisted households to sign up for multiple waiting lists (for example, public housing and Housing Choice Voucher), so this number may include duplicates.

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2. DEVELOPMENT OF THE WORK REQUIREMENT POLICY

Motivation for Instituting the Policy. Staff reported that the motivation for developing a work requirement policy began with a desire to offer more households the opportunity to live in the PHA’s new single-family, scattered-site public housing units. To foster that opportunity, LMHA implemented a policy that combined work or education requirements, a 5-year occupancy term limit, and mandatory case management. The goal of the multipronged policy was to promote and encourage economic progress, help assisted households move toward self-sufficiency, and prevent assisted households from residing in those homes indefinitely.

Staff reported that the new single-family, scattered-site public housing units had modern amenities and a low rent structure, making them highly desirable and sought after by assisted households. The policy was developed with the hope that assisted households in those units could become self-sufficient and move out, thus enabling the PHA to provide more households with the opportunity to live in the new units.

Concerns or Needs Considered During Policy Development. Staff reported that the development of the work requirement policy was driven by concerns that the amenities and low rent structure at the affected properties would discourage assisted households from moving out and that instituting the policy would incentivize assisted households to strive for self-sufficiency. The PHA decided to exempt elderly and disabled assisted households from the policy because of the increased barriers they would face trying to comply with the work or education requirements.

Entities Involved in the Development of the Policy. Details about the development of the work requirement policy were not readily available. Staff noted that the policy had been developed more than a decade ago, and many of the staff that were involved had retired or moved on from the PHA.

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3. DESCRIPTION OF THE WORK REQUIREMENT POLICY

LMHA established a combined work requirement and

Target Population (Inclusion/Exclusion Criteria)

5-year term limit policy in FY 2007 as a condition of



All work-able adults in new single-family,

admission and ongoing occupancy of its new single-

scattered-site public housing units were subject to

family, scattered-site public housing units. The policy

the work requirement/term limit policy.



Elderly and disabled households were exempt from

required that all nondisabled adults between the ages

the employment and term limit requirements.

of 18 and 61 who resided in these housing units had to

work at least 20 hours per week in paid employment or be enrolled as a full-time student in an accredited postsecondary educational institution. The policy also

Activities That Counted Toward the Work

required mandatory participation in case

Requirement

management. No gaps in employment longer than 90



Paid employment:

days were allowed. Elderly and disabled households

o 20+ hours/week.

were exempt from the employment and term limit



Education/training:

requirements but were required to participate in case

o Full-time enrollment at an accredited

postsecondary institution.

management.

Policy Changes. In FY 2010, the work requirement portion of the policy was reduced from 30 hours per week to 20 hours per week due to the state of the local economy at that time, which made finding and retaining jobs difficult for assisted households.

In FY 2014, LMHA implemented an admissions preference to the three-bedroom scattered units for new applicants who were able and willing to meet the work requirement and term limit requirements.

However, the preference did not lead to substantial improvement in occupancy levels. Staff reported that they had difficulty filling the units because—

1. Few work-able assisted households were willing to move into the units due to the term limit.

2. Many work-able assisted households were not employed.

3. Assisted households were required to have the utilities in their name to qualify for these units.

Due to continued low occupancy rates at the sites, the policy was revised in FY 2016 to remove the 5-year term limit and the requirement that assisted households participate in case management. In FY 2017, LMHA also ended the employment or education requirement.

Suspensions of the Policy and Associated Reasons for Suspension. LMHA did not suspend its work requirement policy at any point while it was in place from 2007 to 2017.

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4. IMPLEMENTATION OF THE WORK REQUIREMENT POLICY

Support Services

LMHA’s combined work requirement and term limit

Support Services Provided by LMHA

policy required assisted households to participate in



Mandatory case management.

mandatory case management. Also, less formalized



Workforce development and employment

referrals.

workforce development supports were in place.

Case Management. Assisted households were assigned to a case manager and had to meet with them quarterly. Case managers worked with assisted households to develop a housing goal and, if they lost employment, an employment goal. Staff reported that quarterly meetings were not entirely effective and made ensuring compliance with the policy difficult. Case managers often tried to convince assisted households to participate in the Family Self-Sufficiency (FSS) program, which required monthly meetings with a case manager. Staff believed that assisted households in FSS were generally more successful than those who received quarterly case management.

Workforce Development and Employment Referrals. Staff reported that, although they worked with the local Workforce Investment Board, KentuckianaWorks, they did not have formal contracts in place with it. When appropriate, staff provided assisted households with referrals to local career development centers. Referrals were also made to local employers and to KentuckianaWorks.

Compliance Monitoring

Process for Monitoring Compliance. Property managers were primarily responsible for monitoring compliance, but that task was not done diligently, according to staff. The compliance monitoring process was supposed to involve an annual recertification performed by property management, paired with a quarterly review of employment status by the case manager. Staff noted that when assisted households were sent letters about compliance, they were almost always related to the household’s failure to meet case management requirements.

Work Requirement Policy Compliance Rate. Staff were unable to provide compliance rates for the work requirement for the following reasons: (1) the policy ended more than 4 years ago, (2) compliance was not monitored systematically, and (3) disentangling the work or education requirement from the term limits and other requirements that were bundled together was difficult.

Sanctions for Noncompliance. Staff reported that if assisted households were unable to meet the work or education and term limit policy requirements, the household would be relocated to a different public housing unit that was not subject to the work requirement policy. Staff noted that that it was not always feasible if no public housing units were available. As a result, some assisted households would just stay in the detached single-family units, even though they were not in compliance with the work requirement policy. Staff stated that the possibility of being moved out of the single-family homes after 5 years was a deterrent to some assisted households who wanted to participate in the program but did not want to be moved from their unit.

Sanction Waivers. Because the only “sanctions” involved moving assisted households back into regular public housing units, LMHA had no formal process for sanction waivers.

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5. CHALLENGES, SUCCESSES, AND LESSONS LEARNED

Challenges Implementing the Work Requirement Policy. Staff reported two major challenges with implementing the work and term limit requirement: (1) filling the new single-family, scattered-site public housing units with assisted households willing to participate in the program, and (2) having to transfer assisted households who did not comply back to other public housing units and having limited space to do so.

Successes of the Work Requirement Policy. Staff

Work Requirement Policy Successes

noted that the work requirement was successful in



Helped 19 households move out of assisted housing

helping some assisted households move out of public

and purchase their own home.

housing, with 19 households being able to purchase their own homes. Staff indicated that initially, the program met the agency’s expectations but that over time, it did not achieve the desired outcomes and thus was discontinued.

Assessment of the Policy. LMHA did not conduct or sponsor any third-party evaluations of the work requirement policy. When the policy was in effect, case managers were responsible for keeping track of who was employed. Staff reported that instituting a work requirement led to an increase in the vacancy rate for affected units, as many assisted households failed to meet the eligibility requirements or chose not to participate. As a result, the work requirement policy was sunsetted so that they could lease the units.

Lessons Learned During Implementation and

Maybe we should have tried one thing [work

Monitoring of the Work Requirement Policy.

requirement] and not both [term limits] . . . you

LMHA staff highlighted several lessons learned

need [to have] a good pool of potential residents

from their efforts to implement a work requirement

to make it work.

policy. First, they suggested considering work

requirements for all units rather than just some units.

—LMHA staff member

Second, staff suggested choosing a single policy to

start with—either term limits or a work requirement policy—because implementing both at the same time made compliance too difficult for many assisted households. Third, staff suggested having intensive case management services at the initial stage of policy implementation to establish a relationship with assisted households.

Overall, LMHA staff reported that although the implementation of a work requirement promoted

movement of a few assisted households out of public housing, it was ultimately not a sustainable program for the PHA and was thus discontinued in 2017.

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Housing Authority of the County of San Bernardino

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1. BRIEF BACKGROUND

The Housing Authority of the County of San

All work-able adults at the Maplewood Homes

Bernardino (HACSB) is a public housing agency

Public Housing Community and all work-able

(PHA) in California that serves the County of San

adults in inbound HCV portability households

Bernardino. 99 HACSB joined the U.S. Department

were subject to HACSB’s work requirement

of Housing and Urban Development’s (HUD’s)

policy.

Moving to Work (MTW) Demonstration Program100

in 2008 and instituted its work requirement policy for inbound Housing Choice Voucher (HCV)

portability101 households and residents of the Maplewood Homes Public Housing Community102 in 2010

and 2013, respectively. The goal of HACSB’s work requirement policy was to help assisted households achieve economic self-sufficiency.

HACSB sunsetted the policy for the Maplewood Homes Public Housing Community in 2016 due to the conversion of the site from a public housing site to a project-based voucher site under HUD’s Rental Assistance Demonstration (RAD)103 program. Staff stated that they were unable to mandate a work requirement under the RAD program due to legislative or regulatory restrictions. HACSB also sunsetted the policy for inbound HCV portability households in 2019, citing challenges in administering the policy.

HACSB’s work requirement policy required work-able adults to participate in work-related activities for a minimum of 15 hours per week. HACSB implemented the policy using a three-phased approach of work-related activities for Maplewood Homes Public Housing Community:

 Phase I work-related activities—HACSB allowed activities that removed barriers to gainful

employment for up to 2 years in the program.

 Phase II work-related activities—HACSB allowed activities that led to gainful employment for up to an additional 2 years in the program.

 Phase III work-related activities—HACSB required employment for the remainder of assisted

households’ participation in the program.

HACSB required work-able adults in inbound HCV portability households to comply with phase III of the program before moving to HACSB jurisdiction (i.e., be employed at least 15 hours per week in the County of San Bernadino or within reasonable driving distance). HACSB did not allow those households to participate in phase I or phase II work-related activities.

Work-able adults were defined as individuals who are between the ages of 18 and 61 years and are neither elderly nor have a disability. Adults categorized as elderly or who have a disability were exempt from this 99 For more information about HACSB, see https://hacsb.com/.

100 MTW, launched in 1996, is a HUD demonstration program that provides PHAs with the flexibility to design and test innovative local strategies. For more information about MTW, see https://www.hud.gov/mtw.

101 Portability is a process in the HCV program that allows assisted households to transfer their housing assistance to locations outside the jurisdiction of the PHA that first gave them the subsidy (for more information, see

https://www.hud.gov/program_offices/public_indian_housing/programs/hcv/portability). Work-able assisted households who transferred their housing assistance from other PHA jurisdictions to HACSB, referred to as inbound portability participants, were subject to the work requirement policy.

102 Maplewood Homes Public Housing Community, in the City of San Bernardino, was HACSB’s largest public housing site.

HACSB implemented the work requirement policy at that site as a pilot program.

103 For more information about the RAD program, see https://www.hud.gov/RAD.

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policy. The policy also exempted one adult in assisted households with children younger than 6 years old.

Details about the policy are in Section 3, Description of the Work Requirement Policy .

HACSB served approximately 13,000 households in fiscal year (FY) 2019 and had about 51,000

households on the waiting lists (HACSB, 2019). Staff stated that about 179 work-able adults were subject to the work requirement policy when HACSB instituted it in 2013 for the Maplewood Homes Public Housing Community. 104

This case study details HACSB’s work requirement policy until FY 2019, 105 including development and implementation of the policy, challenges, successes, and lessons learned. The study team summarized the information collected through interviews with HACSB staff and a review of PHA documents, such as annual reports, MTW plans, and other related documents and websites.

104 HACSB tracks the number of assisted households subject to the work requirement policy at the individual level. Data from 2014 to 2021 were not available. Data on the split between the Maplewood Homes Public Housing Community and inbound HCV portability households were also not available.

105 HACSB sunsetted the work requirement policy for work-able inbound HCV portability households in 2019. However, the study team had limited information about the implementation of the policy for this population. Therefore, most information in this case study focuses on HACSB’s pilot work requirement program that was implemented at the Maplewood Homes Public Housing Community from 2013 to 2016.

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2. DEVELOPMENT OF THE WORK REQUIREMENT POLICY

Motivation for Instituting the Policy. HACSB instituted its work requirement policy for inbound HCV

portability households in 2010 and for the Maplewood Homes Public Housing Community in 2013 to help assisted households achieve economic independence.

Desired Policy Outcomes. The goal of HACSB’s work requirement policy was to help assisted households achieve economic self-sufficiency. Specifically, the policy aimed to—

 Increase the income of assisted households.

 Increase the number of households that were employed.

 Reduce assisted households’ reliance on the Temporary Assistance for Needy Families program.

Concerns or Needs Considered During Policy Development. Before developing its work requirement policy for the Maplewood Homes Public Housing Community, HACSB worked with a university partner to conduct a third-party needs assessment of its assisted households. The assessment identified the following concerns or needs of assisted households that HACSB considered during the development of the work requirement policy (HACSB, 2012):

 Chronic Unemployment—Many assisted households reported being unemployed for long periods due to issues such as substance abuse; mental health issues; and lack of job skills, basic computer skills, or transportation. Staff noted that acknowledgment of those challenges led to the development of the three-phased approach of work-related activities.

 Childcare—Many assisted households reported challenges accessing childcare services, so the PHA chose to design the policy to exclude one adult in households with children younger than 6 years old.

Details about the supportive services and resources that HACSB provided to assisted households to address those barriers and challenges are in the Implementation of the Work Requirement Policy section.

Entities Involved in the Development of the Policy. HACSB staff developed the work requirement policy in collaboration with the San Bernardino County Workforce Development Department (WDD) and the San Bernardino County Transitional Assistance Department (TAD). Staff reported that WDD provided input on workforce development activities and resources. Similarly, TAD, which runs the county’s Welfare-to-Work program, provided input on self-sufficiency activities and resources. HACSB developed a data-sharing agreement with TAD because many assisted households also participated in the Welfare-to-Work program. That agreement helped the two agencies better target their resources to meet the needs of assisted households. In addition, HACSB contracted with a university to conduct a third-party needs assessment of assisted households that would be subject to the policy. The findings of the assessment helped inform HACSB’s three-phased approach in implementing the work requirement policy. The

university partner also assisted in identification of community partners and supportive resources.

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3. DESCRIPTION OF THE WORK REQUIREMENT POLICY

HACSB’s work requirement policy required all work-

Target Population (Inclusion/Exclusion Criteria)

able adults, defined as individuals who were between



All work-able adults at the Maplewood Homes

the ages of 18 and 61 years and did not have a

Public Housing Community and all work-able

disability, to participate in work-related activities for

adults in inbound HCV portability households were

subject to HACSB’s work requirement policy.

at least 15 hours per week. The policy applied to all

 Elderly and disabled households were excluded.

work-able adults at the Maplewood Homes Public

 One adult in assisted households with children

Housing Community and in inbound HCV portability

younger than 6 years old was also excluded.

households.

For assisted households at the Maplewood Homes

Activities That Counted Toward the Work

Public Housing Community, HACSB implemented

Requirement

the policy using a three-phased approach to work-

Phase I: Activities that removed barriers to gainful

related activities. In phase I, HACSB allowed assisted

employment—

households to engage in activities that removed

o Volunteer work, skills training, GED classes,

substance abuse treatment, and mental health

barriers to gainful employment—such as volunteer

services.

work, skills training, GED classes, substance abuse

o Allowed for up to 2 years.

treatment, and mental health services—for up to 2

Phase II: Activities that led to gainful employment—

years. After 2 years, HACSB required assisted

o Vocational training, apprenticeship, and

households to transition to either phase II or phase III.

enrollment in an educational program.

o Allowed for up to 2 years.

In phase II of the program, HACSB allowed assisted

Phase III: Paid employment—

households to engage in activities that led to gainful

o 15+ hours/week.

employment—such as vocational training,

apprenticeship, and enrollment in an educational program—for up to 2 years. Similar to the requirement in phase I, HACSB required assisted households to transition to phase III after 2 years in phase II. In phase III, HACSB required assisted households to work at least 15 hours per week, earning no less than California’s minimum wage, for the remainder of their time in the program. HACSB also required work-able adults in inbound HCV portability households to work at least 15 hours per week in the county of San Bernadino or within reasonable driving distance of the county. HACSB did not allow those

households to participate in phase I or phase II work-related activities.

Policy Changes. HACSB did not implement any policy changes from the time the work requirement policy went into effect in 2010 until HACSB sunsetted the policy in 2019. HACSB sunsetted the policy for the Maplewood Homes Public Housing Community in 2016 due to the conversion of the site from a public housing site to a project-based voucher site under the RAD program. Staff stated that the work requirement was not allowed under the RAD program. HACSB also sunsetted the policy for inbound HCV portability households in 2019, citing challenges in administering the policy.

Suspensions of the Policy and Associated Reasons for Suspension. HACSB did not suspend its work requirement policy from the time the policy went into effect in 2010 until it sunsetted the policy in FY

2019.

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4. IMPLEMENTATION OF THE WORK REQUIREMENT POLICY

Support Services

Working with the local partners listed in exhibit B.17,

Support Services Provided by HACSB and Its

HACSB provided a range of supportive services and

Community Partners

resources to help assisted households achieve



Workforce development services.

economic self-sufficiency. Those partnerships helped



Self-sufficiency services.



Social services referrals.

HACSB leverage community resources to better meet



Case management.

the needs of assisted households. Support services

included the following:

 Workforce Development Services. HACSB contracted with WDD for onsite workforce development services. WDD staff visited the Maplewood Homes Public Housing Community once a week to

provide services such as job search and placement, resume writing, career assessment and counseling, interviewing techniques, and training referrals.

 Self-Sufficiency Services. HACSB hired an onsite staff member to provide self-sufficiency coaching and referral services. The staff member was located at the Maplewood Homes Public Housing

Community and provided services such as one-on-one coaching, needs assessment, and referral and coordination of social services. TAD staff also visited the Maplewood Homes Public Housing

Community once a week to help connect assisted households with TAD resources, such as job

training, transportation assistance, childcare assistance, and education assistance.

 Social Services Referrals. Knowledge and Education for Your Success, a nonprofit organization founded by HACSB, helped assisted families access various social services, including mental health, substance abuse, childcare, financial literacy, and healthcare services.

 Case Management. Loma Linda University interns provided case management services to assisted households who were referred by HACSB staff. Households also received support in establishing goals and developing plans to achieve them.

Exhibit B.17. Selected HACSB Implementation Partners

Name of Partner

Type of Organization Supportive Services Provided

1. San Bernardino County Workforce

Job readiness, job training, job

Development Department

Government agency

search and placement, and

career counseling.

2. San Bernardino County Transitional

Assistance Department

Government agency

Job placement, adult literacy,

and vocational counseling.

3. Knowledge and Education for Your

Social services

Case management and social

Success

provider

services referrals.

4. Loma Linda University

Educational institution Case management.

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Compliance Monitoring

Process for Monitoring Compliance. HACSB required assisted households to recertify compliance on an annual basis. For assisted households at the Maplewood Homes Public Housing Community, an onsite HACSB coach conducted recertification. For inbound HCV portability households, an HACSB housing services specialist conducted recertification. For assisted households who HACSB determined to be noncompliant with the work requirement policy, HACSB gave them 90 days to become compliant. If a household failed to come into compliance after the initial 90 days, HACSB gave them an additional 90

days, after which it imposed sanctions.

Work Requirement Policy Compliance Rate. Information regarding HACSB’s compliance rate was limited—data were only available for September 2013. In that month, staff reported that about 69 percent of assisted households at the Maplewood Homes Public Housing Community were compliant with the work requirement. 106

Sanctions for Noncompliance. For assisted households at the Maplewood Homes Public Housing Community who were noncompliant, HACSB increased the rent for their housing unit to the market rate.

For inbound HCV portability households who were noncompliant, HACSB imputed their previous

employment income when determining their rent subsidy until they obtained new employment.

Sanction Waivers. Information regarding HACSB’s sanction waivers was not available.

106 HACSB measured compliance rates on the basis of the number of work-able adults participating in work-related activities; in September 2013, staff reported that 123 work-able adults at the Maplewood Homes Public Housing Community (of 179 work-able adults subject to the work requirement) were participating in work-related activities.

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5. CHALLENGES, SUCCESSES, AND LESSONS LEARNED

Challenges Implementing the Work Requirement Policy. Staff reported that monitoring compliance was administratively burdensome and time consuming. The onsite self-sufficiency coach spent a lot of time on administrative tasks such as verifying and following up on compliance paperwork, leaving limited time for providing support services. HACSB did not have funding to hire additional staff to support administrative tasks. However, it leveraged partnerships with agencies such as WDD and TAD to ensure that assisted households received the support services they needed.

Successes of the Work Requirement Policy. Staff

Key Success of HACSB’s Work Requirement

noted that the program was successful in helping

Policy

assisted households achieve positive outcomes. They



Average income for assisted households increased

reported that in FY 2016, the average income for

by more than 14 percent in FY 2016 compared with

assisted households had increased by more than 14

the level before policy implementation.



The number of heads of household employed

percent compared with the level before

increased by more than 19 percent in FY 2016

implementation of the work requirement policy.

compared with the level before policy

Similarly, in the same year, the number of heads of

implementation.

household employed increased by more than 19 percent compared with the level before implementation of the work requirement.

Assessment of the Policy. HACSB did not conduct a study of its work requirement. However, HACSB

contracted Loma Linda University to conduct a needs assessment study of the Maplewood Homes Public Housing Community that compared the needs of residents at the site between 2010 and 2016. Loma Linda University also conducted a longitudinal study of HACSB’s 5-Year Lease Assistance Program. 107 The study followed assisted households over time and tracked various outcomes, including household income, employment status, education, health, program exit, and self-sufficiency.

Lessons Learned During Implementation and

Monitoring of the Work Requirement Policy.

The messaging and how you go about that, how

you plan to help families be successful on

HACSB staff asserted that when developing a work

whatever initiative that you design, that needs to

requirement policy, ensuring that PHA staff are well

be the end goal that you have in mind. It’s not

informed about the design, requirements, and goals

intended to be punitive or penalize them, but how

of the policy is important. In return, PHA staff will

are we going to make sure that families can be as

be able to effectively communicate and educate

successful as they possibly can be on this activity.

It is an activity that should be designed to make a

assisted households on the work requirement, which

positive difference.

will aid PHAs in obtaining buy-in from staff and

assisted households. HACSB staff also stated that

—HACSB Staff Member

PHAs must do their due diligence to ensure that

they have a clear understanding of the administrative burden and the cost of implementing a work requirement.

Overall, HACSB staff believed that their work requirement policy helped assisted households achieve positive outcomes despite the administrative challenges and funding limitations.

107 For more information about HACSB’s 5-Year Lease Assistance program, see https://hacsb.com/types-of-affordable-housing/.

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U.S. Department of Housing and Urban Development

Office of Policy Development and Research

Washington, DC 20410-6000

April 2024

Document Outline

A Review of Work Requirement Policies in HUD-Funded Assisted Housing Final Research Report

DISCLAIMER

FOREWORD

TABLE OF CONTENTS

1. INTRODUCTION

Study Approach to Addressing the Research Objective

2. LITERATURE REVIEW

Temporary Assistance for Needy Families

Supplemental Nutrition Assistance Program

Medicaid

Housing Assistance

3. FINDINGS FROM KEY STAKEHOLDER INTERVIEWS

Designing a Work Requirement Policy for HUD-Funded Assisted Housing

Implementation and Monitoring of a Work Requirement Policy for HUD-Funded Assisted Housing

Desired Outcomes of a Work Requirement Policy in HUD-Funded Assisted Housing

4. CASE STUDIES SYNTHESIS AND KEY FINDINGS

Overview of Nine PHAs and Their Work Requirement Policies

Development of a Work Requirement Policy

Implementation of a Work Requirement Policy

5. CONCLUSION

APPENDIX A: DETAILS OF LITERATURE REVIEW

1. Searching Literature

2. Reviewing Full-Text Literature

APPENDIX B: CASE STUDIES OF MTW PHAS WITH A WORK REQUIREMENT

Atlanta Housing

Housing Authority of Champaign County

INLIVIAN (formerly Charlotte Housing Authority)

Chicago Housing Authority

Delaware State Housing Authority

Lawrence-Douglas County Housing Authority

Lexington-Fayette Urban County Housing Authority

Louisville Metro Housing Authority

Housing Authority of the County of San Bernardino

REFERENCES

Table of Contents

A Review of Work Requirement Policies in HUD-Funded Assisted Housing Final Research Report

DISCLAIMER

FOREWORD

TABLE OF CONTENTS

1. INTRODUCTION

Study Approach to Addressing the Research Objective

2. LITERATURE REVIEW

Temporary Assistance for Needy Families

Supplemental Nutrition Assistance Program

Medicaid

Housing Assistance

3. FINDINGS FROM KEY STAKEHOLDER INTERVIEWS

Designing a Work Requirement Policy for HUD-Funded Assisted Housing

Implementation and Monitoring of a Work Requirement Policy for HUD-Funded Assisted Housing

Desired Outcomes of a Work Requirement Policy in HUD-Funded Assisted Housing

4. CASE STUDIES SYNTHESIS AND KEY FINDINGS

Overview of Nine PHAs and Their Work Requirement Policies

Development of a Work Requirement Policy

Implementation of a Work Requirement Policy

5. CONCLUSION

APPENDIX A: DETAILS OF LITERATURE REVIEW

1. Searching Literature

2. Reviewing Full-Text Literature

APPENDIX B: CASE STUDIES OF MTW PHAS WITH A WORK REQUIREMENT

Atlanta Housing

Housing Authority of Champaign County

INLIVIAN (formerly Charlotte Housing Authority)

Chicago Housing Authority

Delaware State Housing Authority

Lawrence-Douglas County Housing Authority

Lexington-Fayette Urban County Housing Authority

Louisville Metro Housing Authority

Housing Authority of the County of San Bernardino

REFERENCES