Evaluation of the Moving to Work Flexibility Cohort

Year 2 Report

DISCLAIMER

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

Evaluation of the Moving to Work Flexibility Cohort:

Year 2 Report

Prepared for

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

Prepared by

Abt Associates Inc. Tanya de Sousa Judy Geyer Larry Buron Keely Stater Laura Peck

September 22, 2023

Acknowledgments

The authors would like to thank the staff of the Flexibility Cohort public housing agencies that participated in our webinar and took time out of their busy schedules to talk to interviewers. The authors thank Anne Fletcher, the U.S. Department of Housing and Urban Development (HUD) Contracting Officer Representative for her support and feedback and the Office of Policy Development and Research staff that provided comments on the draft and at a briefing. We also thank Lynn Rodgers and Quincy Riley at HUD for providing the study with Public and Indian Housing Information Center and Financial Data System data.

In addition to the authors, Abt Associates Inc. staff that worked on this report include data analysts Tyler Morrill and Doug Walton and interviewers Liz Yadav, Kasonde Chisaka, Zoe Greenwood, and Zoya Aleem. The authors also appreciate the helpful feedback on report drafts from Jill Khadduri and consultant Amy Ginger. Bry Pollack provided editorial suggestions. Chris Kubacki of Phineas Consulting provided guidance on using the administrative cost data.

Foreword

Moving to Work (MTW) is a demonstration program for public housing agencies (PHAs) that provides the flexibility to test innovative, locally designed strategies that can help PHAs use federal dollars more efficiently, help residents find employment and become self-sufficient, and increase housing choices for low-income families. MTW allows PHAs exemptions from many existing public housing and voucher rules and provides flexibility with how they use federal funds. In 2016, the U.S. Congress directed the U.S. Department of Housing and Urban Development (HUD) to expand the MTW demonstration by 100 agencies, with an emphasis on ensuring that the expansion included rigorous evaluation of the innovative solutions the MTW flexibilities made possible.

This report is part of a multi-year research project that aims to understand how MTW regulatory flexibilities impact smaller PHAs and the households they serve. This report describes the second year of MTW designation for the PHAs participating in the initial cohort of the MTW expansion. This cohort, known as the “Flexibility Cohort,” includes 31 “smaller” high-performing PHAs, each administering 1,000 or fewer combined public housing and housing choice voucher units. It is the third of a series of five annual evaluation reports that will track the progress of the Flexibility Cohort. Previous reports include the Baseline Report , which explored PHAs’ motivations for participating in MTW and how they planned to use MTW flexibilities, and the Year 1 Outcomes Report , which summarized how PHAs navigated the onboarding process and provided a contextual look at the outcome measures to be used during the course of the evaluation.

In this Year 2 Outcomes Report, data was collected through interviews, administrative records, and secondary data sources during 2022 to assess potential progress toward achieving the three statutory objectives of MTW: cost-effectiveness, self-sufficiency, and housing choice. By the end of 2022, 26 of the 31 PHAs had approved MTW Supplements, allowing them to take advantage of the MTW flexibility. The process study details specific waivers the PHAs selected to take advantage of the MTW flexibility. In many cases, PHAs intend to use the MTW flexibilities as part of a broader plan to implement several waiver activities directed toward meeting the three statutory objectives.

In addition to the process study, this report begins examining outcome measures associated with the three statutory objectives. It is too early in the implementation stage to make conclusions regarding program impacts because many MTW activities have only been in operation for less than 6 months. However, the interim impact analysis lays the groundwork for future evaluations.

As these new MTW agencies move forward, HUD will continue to document program implementation and share what is learned about the impacts in the coming years.

Solomon Greene Principal Deputy Assistant Secretary for Policy Development and Research U.S. Department of Housing and Urban Development

Table of Contents

Executive Summary ............................................................................................................................... viii

Overview of Flexibility Cohort and Evaluation ................................................................................. viii

How Do Smaller Public Housing Agencies Use Moving to Work Flexibility? ................................... ix

What are the Impacts of Moving to Work Flexibility on Smaller Public Housing Agencies and Their

Residents? .................................................................................................................................. xii

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

1.1 Content of This Report ............................................................................................................... 1

1.2 Evaluation Design and Data Sources .......................................................................................... 2

1.3 Status of Flexibility Cohort Moving to Work Public Housing Agencies .................................... 5

2. Moving to Work Supplement Process and Approved Waivers Across Public Housing Agencies ........................................................................................................................................................... 7

2.1 Overview of the Moving to Work Supplement Process .............................................................. 7

2.2 Public Housing Agency Experiences Completing the Moving to Work Supplement ................. 9

2.3 Approved Moving to Work Waivers and Activities Across Public Housing Agencies ............. 11

2.4 Use of Funding Flexibility to Support Moving to Work Activities ........................................... 30

2.5 Public Housing Agencies Without an Approved Moving to Work Supplement ....................... 31

2.6 Lessons Learned and Recommendations .................................................................................. 31

3. Approved Moving to Work Activities by Targeted Moving to Work Objectives ...................... 34

3.1 Number of Approved Waivers by Public Housing Agency ...................................................... 34

3.2 Approved Public Housing Agency Activities to Promote Cost-Effectiveness .......................... 35

3.3 Approved Public Housing Agency Activities to Promote Self-Sufficiency .............................. 38

3.4 Approved Public Housing Agency Activities to Promote Housing Choice .............................. 42

3.5 Timeline for Implementing Activities ....................................................................................... 45

4. Changes Over Time, Control Group Activities, and Significant Legislation ............................. 47

4.1 Summary of Planned Activities Compared with Earlier Moving to Work Plans ...................... 47

4.2 Activities Undertaken by Non-Moving to Work Public Housing Agencies (Control Group) ... 49

4.3 Effect of Housing Opportunity Through Modernization Act Changes ..................................... 50

5. Interim Impacts on Outcome Measures ....................................................................................... 52

5.1 Confirmatory Outcomes ........................................................................................................... 53

5.2 Exploratory Outcomes .............................................................................................................. 57

6. Summary of Findings for Research Questions ............................................................................. 59

6.1 How Do Smaller Public Housing Agencies Use Moving to Work Flexibility? ........................ 59

6.2 What Are the Impacts of Moving to Work Flexibility on Smaller Public Housing Agencies and Their Residents? ....................................................................................................................... 61

Appendix A. Maps of Moving to Work Flexibility Cohort Public Housing Agencies and Control Public Housing Agencies ................................................................................................................ 62

Appendix B. Profiles for 26 Flexibility Cohort Public Housing Agencies with Approved Moving to Work Supplements ......................................................................................................................... 65

Appendix C. Exploratory Impact Analysis ......................................................................................... 115

Appendix D. Impact Analysis Methodology ....................................................................................... 121

References ............................................................................................................................................. 123 List of Exhibits

Exhibit 1-1. Timing of First Approved Moving to Work Supplement as of March 31, 2023 ...................... 5

Exhibit 2-1. Categories of Moving to Work Preapproved Waivers ............................................................. 7

Exhibit 2-2. MTW Waivers Selected by the 26 PHAs With Approved MTW Supplements ..................... 11

Exhibit 2-3. Applying Moving to Work Flexibility to Special Purpose Vouchers .................................... 12

Exhibit 2-4. Approved Activities to Adjust Tenant Rent Policies ............................................................. 13

Exhibit 2-5. Approved Activities to Adjust Payment Standards and Rent Reasonableness....................... 15

Exhibit 2-6. Approved Activities to Adjust the Reexamination Process ................................................... 17

Exhibit 2-7. Implementing Alternative Reexamination Schedules ............................................................ 18

Exhibit 2-8. Approved Activities to Implement Landlord Leasing Incentives .......................................... 19

Exhibit 2-9. How Public Housing Agencies Use Other Landlord Leasing Incentives Waivers ................ 20

Exhibit 2-10. Approved Activities to Adjust Housing Quality Standards Processes ................................. 21

Exhibit 2-11. Approved Activities to Implement Project-Based Voucher Program Flexibilities .............. 23

Exhibit 2-12. Approved Activities to Adjust the Family Self-Sufficiency Program ................................. 25

Exhibit 2-13. Approved Activities to Implement a Moving to Work Self-Sufficiency Program ............... 26

Exhibit 2-14. Approved Activities to Implement Local, Nontraditional Activities ................................... 28

Exhibit 2-15. Challenges in Transitioning to the New Housing Information Portal .................................. 33

Exhibit 3-1. Number of Moving to Work Waivers Among the 26 Public Housing Agencies With Approved Moving to Work Supplements ........................................................................ 35

Exhibit 3-2. Administrative Efficiency Activities to Promote Cost-Effectiveness for Public Housing Agencies (PHAs) With Three or More Approved Activities ( n = 12) ............... 37

Exhibit 3-3. Self-Sufficiency Activities for Public Housing Agencies (PHAs) With Multiple Self-Sufficiency Activities ( n = 12) ........................................................................................ 40

Exhibit 3-4. Landlord Incentive Activities for Public Housing Agencies (PHAs) to Promote Housing Choice ( n = 14) ................................................................................................. 43

Exhibit 3-5. Implementation Timing of Approved Moving to Work Activities ........................................ 46

Exhibit 4-1. Flexibility Cohort Public Housing Agencies’ (PHA) Plans for Moving to Work (MTW) Waiver Use Over Time From Baseline to Year 2............................................... 48

Exhibit 5-1. Confirmatory and Exploratory Outcomes ............................................................................. 52

Exhibit 5-2. Moving to Work Treatment, Control, and Comparison Groups and Related Impacts ........... 53

Exhibit 5-3. Estimated Impacts of Offering Moving to Work Cohort 1 Designation, Year 2 (2022) ........ 54

Exhibit 5-4. Quarterly Earnings Over Time for Households in Treatment, Control, and Comparison Public Housing Agencies ................................................................................................ 55

Exhibit A-1. Map of 31 Moving to Work Flexibility Cohort Public Housing Agencies ........................... 63

Exhibit A-2. Map of 10 Control Group PHAs (Numbered) Relative to Flexibility Cohort PHAs (not Numbered) ............................................................................................................... 64

Exhibit B-1(a). Background Information for Sheffield Housing Authority ............................................... 65

Exhibit B-1(b). Approved MTW Waivers as of March 31, 2023, for Sheffield Housing Authority (AL-068) ......................................................................................................................... 65

Exhibit B-2(a). Background Information for Ozark Housing Community (AL-073) ................................ 66

Exhibit B-2(b). Approved MTW Waivers as of March 31, 2023, for Ozark Housing Community

(AL-073) ......................................................................................................................... 66

Exhibit B-3(a). Background Information for Pomona Housing Authority (CA-123) ................................ 67

Exhibit B-3(b). Approved MTW Waivers as of March 31, 2023, for Pomona Housing Authority

(CA-123) ......................................................................................................................... 68

Exhibit B-4(a). Background Information for Solano County Housing Authority (CA-131) ..................... 69

Exhibit B-4(b). Approved MTW Waivers as of March 31, 2023, for Solano County Housing Authority (CA-131) ......................................................................................................... 70

Exhibit B-5(a). Background Information for Brighton Housing Authority (CO-019) ............................... 71

Exhibit B-5(b). Approved MTW Waivers as of March 31, 2023, for Brighton Housing Authority (CO-019) ......................................................................................................................... 71

Exhibit B-6(a). Background Information for the New Smyrna Beach Housing Authority (FL-022) ........ 73

Exhibit B-6(b). Approved MTW Waivers as of March 31, 2023, for the New Smyrna Beach Housing Authority (FL-022) ........................................................................................... 74

Exhibit B-7(a). Background Information for the Housing Authority of Newnan (GA-095) ..................... 76

Exhibit B-7(b). Approved MTW Waivers as of March 31, 2023, for the Housing Authority of Newnan (GA-095)........................................................................................................... 76

Exhibit B-8(a). Background Information for the Housing Alliance and Community Partnerships (ID-005) .......................................................................................................................... 77

Exhibit B-8(b). Approved MTW Waivers as of March 31, 2023, for the Housing Alliance and Community Partnerships (ID-005) .................................................................................. 78

Exhibit B-9(a). Background Information for Ruston Housing Authority (LA-054) .................................. 81

Exhibit B-9(b). Approved MTW Waivers as of March 31, 2023, for Ruston Housing Authority (LA-054) ......................................................................................................................... 82

Exhibit B-10(a). Background Information for Rockville Housing Enterprises (MD-007) ........................ 84

Exhibit B-10(b). Approved MTW Waivers as of March 31, 2023, for Rockville Housing Enterprises (MD-007) ..................................................................................................... 84

Exhibit B-11(a). Background Information for the Housing Redevelopment Authority of Hibbing (MN-004) ........................................................................................................................ 87

Exhibit B-11(b). Approved MTW Waivers as of March 31, 2023, for the Housing and Redevelopment Authority of Hibbing (MN-004) ............................................................ 87

Exhibit B-12(a). Background Information for Kandiyohi County Housing and Redevelopment

Authority (MN-168) ........................................................................................................ 88

Exhibit B-12(b). Approved MTW Waivers as of March 31, 2023, for Kandiyohi County Housing

and Redevelopment Authority (MN-168) ....................................................................... 88

Exhibit B-13(a). Background Information for McLeod County Housing and Redevelopment Authority (MN-203) ........................................................................................................ 89

Exhibit B-13(b). Approved MTW Waivers as of March 31, 2023, for McLeod County Housing and Redevelopment Authority (MN-203) .............................................................................. 89

Exhibit B-14(a). Background Information for Washington County Community Development Agency (MN-212) ........................................................................................................... 90

Exhibit B-14(b). Approved MTW Waivers as of March 31, 2023, for Washington County Community Development Agency (MN-212) ................................................................. 90

Exhibit B-15(a). Background Information for Ripley County Public Housing Agency (MO-212) ........... 91

Exhibit B-15(b). Approved MTW Waivers as of March 31, 2023, for Ripley County Public Housing Agency (MO-212) ............................................................................................ 91

Exhibit B-16(a). Background Information for Robeson County Housing Authority (NC-084) ................ 93

Exhibit B-16(b). Approved MTW Waivers as of March 31, 2023, for Robeson County Housing Authority (NC-084) ......................................................................................................... 93

Exhibit B-17(a). Background Information for South Sioux City Housing Agency (NE-175) ................... 95

Exhibit B-17(b). Approved MTW Waivers as of March 31, 2023, for South Sioux City Housing Agency (NE-175) ............................................................................................................ 95

Exhibit B-18(a). Background Information for Dover Housing Authority (NH-003) ................................. 96

Exhibit B-18(b). Approved MTW Waivers as of March 31, 2023, for Dover Housing Authority (NH-003) ......................................................................................................................... 97

Exhibit B-19(a). Background Information for Housing Authority of Cheraw (SC-031) ........................... 98

Exhibit B-19(b). Approved MTW Waivers as of March 31, 2023, for Housing Authority of Cheraw (SC-031) ......................................................................................................................... 99

Exhibit B-20(a). Background Information for Maryville Housing Authority (TN-065)............................ 99

Exhibit B-20(b). Approved MTW Waivers as of March 31, 2023, for Maryville Housing Authority (TN-065) ....................................................................................................................... 100

Exhibit B-21(a). Background Information for the Housing Authority of Travis County (TX-480) ........ 101

Exhibit B-21(b). Approved MTW Waivers as of March 31, 2023, for the Housing Authority of Travis County (TX-480) ............................................................................................... 101

Exhibit B-22 (a). Background Information for Rosenberg Housing Authority (TX-483) ....................... 102

Exhibit B-22(b). Approved MTW Waivers as of March 31, 2023, for Rosenberg Housing Authority (TX-483) ....................................................................................................... 103

Exhibit B-23(a). Background Information for Bristol Redevelopment Housing Authority (VA-002) .... 104

Exhibit B-23(b). Approved MTW Waivers as of March 31, 2023, for Bristol Redevelopment and Housing Authority (VA-002) ........................................................................................ 105

Exhibit B-24(a). Background Information for Harrisonburg Redevelopment Housing Authority (VA-014) ....................................................................................................................... 108

Exhibit B-24(b). Approved MTW Waivers as of March 31, 2023, for Harrisonburg Redevelopment HA (VA-014) ................................................................................................................ 108

Exhibit B-25(a). Background Information for Brattleboro Housing Authority (VT-002) ....................... 112

Exhibit B-25(b). Approved MTW Waivers as of March 31, 2023, for Brattleboro Housing

Authority (VT-002) ....................................................................................................... 113

Exhibit B-26(a). Background Information for Randolph County Housing Authority (WV-045) ............ 113

Exhibit B-26(b). Approved MTW Waivers as of March 31, 2023, for Randolph County Housing Authority (WV-045) ..................................................................................................... 114

Exhibit C-1. Estimated Impacts on PHA Cost-Effectiveness (Dollars per Household per Month) ......... 115

Exhibit C-2. Estimated Impacts on Nonelderly, Nondisabled Household Earnings and Employment and Earnings ................................................................................................................. 115

Exhibit C-3. Estimated Impacts on Household Housing Choice: Low-Poverty Rate of Household Census Tracts ................................................................................................................ 116

Exhibit C-4. Estimated Impacts on Household Housing Choice: Public Housing Agency Supply of Quality, Affordable Rental Units .................................................................................. 116

Exhibit C-5. Estimated Impacts on Household Housing Choice, Hard-to-House Populations ................ 117

Exhibit C-6. Estimated Impacts on Other Tenant Outcomes: Households Served .................................. 117

Exhibit C-7. Estimated Impacts on Other Tenant Outcomes: Households Exit ...................................... 118

Exhibit C-8. Estimated Impacts on Other Outcomes: Rent Burden in Public Housing ........................... 119

Exhibit C-9. Estimated Impacts on Other Outcomes: Rent Burden in Housing Choice Voucher Program ......................................................................................................................... 120 Executive Summary

Moving to Work (MTW) is a HUD demonstration program that gives public housing agencies (PHAs) statutory and regulatory flexibility to test ways to achieve the program’s three statutory objectives of increasing the cost-effectiveness of federal housing programs, encouraging greater self-sufficiency of households receiving housing assistance, and increasing housing choices for low-income families. In addition to statutory and regulatory flexibility around practices and policies, MTW PHAs also get funding flexibility, letting them use their allocated funding for the Housing Choice Voucher (HCV) and public housing programs for any allowable use under either program or for local, nontraditional (LNT) activities. 1

The MTW demonstration was authorized by Congress in 1996. In 2016, Congress directed HUD to expand the MTW demonstration by 100 PHAs and required HUD to set aside 50 slots for smaller PHAs, defined as agencies administering 1,000 or fewer combined HCV and public housing units. At that time, 39 PHAs already had MTW designation, and only 1 had fewer than 1,000 units. HUD is adding the 100 new MTW PHAs to the demonstration in cohorts, each testing a different policy change. 2

The first cohort of the MTW expansion—the subject of this report—is limited to smaller PHAs that are designated as high performers and not troubled under either the Public Housing Assessment System (PHAS) or Section 8 Management Assessment Program at selection. 3 For this cohort, HUD determined that the policy focus of the MTW expansion would be to observe how smaller PHAs use the full array of MTW flexibilities and how these flexibilities affect PHAs and assist households. The primary purpose of studying this expansion cohort, referred to as the Flexibility Cohort, is to test the overall impact of MTW flexibility on smaller PHAs. Overview of Flexibility Cohort and Evaluation

The Flexibility Cohort. The selection of the 31 PHAs in the Flexibility Cohort was finalized in 2021, following a two-part application process. HUD released a selection notice for the Flexibility Cohort in October 2018. Forty-three PHAs completed the initial letter of interest process from 2018 to 2019 and met the eligibility requirements for this first cohort of the MTW expansion.

HUD randomly assigned the 43 PHAs to either a treatment group (33 Treatment PHAs) or a control group (10 Control PHAs). The 33 Treatment PHAs were invited to apply for MTW designation. The 10 Control PHAs were not offered the opportunity to apply for MTW designation under the first cohort but were offered the opportunity to apply to future cohorts.

1 MTW PHAs must also comply with five statutory requirements: (1) the Secretary must establish or approve Housing Quality Standards applied under MTW; (2) 75 percent of families served must be very low income; (3)

agencies must establish a reasonable rent policy designed to encourage work and self-sufficiency; (4) agencies must continue to assist substantially the same number of families as they would have if not designated MTW; and (5) agencies must maintain a comparable mix of families by size if not designated MTW. Section 239 of the Consolidated Appropriations Act, 2016 (Public Law 114-113). 2

3 For more information about PHAS, see https://www.hudexchange.info/sites/onecpd/assets/File/PHA-Lead-the-Way-Understanding-PHAS.pdf . For more information about the Section 8 Management Assessment Program, see https://www.hud.gov/program_offices/public_indian_housing/programs/hcv/semap . By the close of the application period, 31 of the 33 Treatment PHAs submitted MTW applications to HUD. In January 2021, HUD offered MTW designation to these 31 PHAs, forming the Flexibility Cohort.

The Evaluation of the Flexibility Cohort. The evaluation of this cohort includes both a process and impact study. This mixed-methods evaluation aims to answer two questions—

• How do smaller PHAs use their MTW flexibility? How does MTW flexibility impact smaller PHAs and their residents? •

The process study addresses the first question, and this report uses data from MTW Supplements approved by the end of March 2023 and PHA staff interviews in February and March 2023 to share process study findings to date. The impact study addresses the second question, and this report uses HUD administrative data from 2022—the second year after being offered the opportunity to become an MTW PHA and the first full year when most of these PHAs were officially designated as MTW PHAs—to share impact study findings to date.

Status of Flexibility Cohort PHAs at Time of This Report. A PHA is not designated an MTW PHA until fully executing an amendment to its Annual Contributions Contract (ACC), the vehicle through which HUD provides funds for the HCV and public housing programs. Once the MTW ACC Amendment is in place, a PHA has funding flexibility starting in the following month. The funding streams that may be used flexibly are (1) public housing Operating Fund grants, (2) public housing Capital Fund grants, (3) HCV Housing Assistance Payment funds, and (4) HCV administrative fee funds. By February 2022, all 31 Flexibility Cohort PHAs had fully executed an MTW ACC Amendment.

Implementing any activities requiring MTW Waivers takes another step beyond the MTW ACC Amendment. The PHA must complete (and receive HUD approval of) the MTW Supplement to the PHA Annual Plan, describing its plans for the fiscal year. By the end of 2022, 26 of the 31 Flexibility Cohort PHAs had approved MTW Supplements, allowing them to start implementing MTW activities. However, only 13 PHAs had an approved MTW Supplement by the middle of 2022, meaning that less than half of the Flexibility Cohort PHAs had the opportunity to begin implementing their MTW activities for at least 6 months by the time outcomes were measured for this report. As a result, it is unlikely that MTW activities were operational for a sufficient length of time to lead to program impacts. How Do Smaller Public Housing Agencies Use Moving to Work Flexibility?

Although early in the implementation stage, Flexibility Cohort PHAs made robust use of MTW flexibility to make changes in their programs. All but one PHA with an approved MTW Supplement received approval for multiple MTW Waivers, with some representing substantial departures from standard procedures. Most PHAs in this cohort did not only obtain approval for minor programmatic or administrative changes but combined several MTW Waivers into an overall strategy for improving housing assistance programs.

PHAs made limited use of funding flexibility in their current strategies. Approximately one-third (11) of the 31 Flexibility Cohort PHAs used funding flexibility to support MTW activities by distributing funds among their public housing and HCV funding streams. Volume of Waivers. All 31 Flexibility Cohort PHAs had MTW funding flexibility by the end of 2021 or early 2022, and 26 of the 31 PHAs had approved MTW Supplements with waivers, allowing them to conduct activities that standard PHAs cannot.

• Among the 26 PHAs with an approved MTW Supplement, 236 MTW Waivers were approved for implementation.

• The median number of MTW Waivers is 8 per PHA, with three PHAs having 20 or more approved waivers and three PHAs having 3 or fewer approved waivers.

• All but 1 of the 236 approved waivers were included in the list of 70 preapproved waivers in the MTW Operations Notice (HUD, 2020). One PHA has an agency-specific waiver.

Cost-Effectiveness Objective. Of the 26 PHAs with approved MTW Supplements, 24 have waivers for an administrative efficiency activity that reduces staff time, which could improve cost-effectiveness. Half of those 24 PHAs have approval for three or more such activities. Many PHAs had deliberate strategies for creating cost-savings through administrative efficiencies so that the savings could be applied to activities that increase self-sufficiency or housing choice.

• The most common activity to improve administrative efficiency—reducing the frequency of reexaminations (18 PHAs)—is a substantial change to the program that could considerably reduce the amount of staff time on reexaminations and administrative burden on assisted households, allowing households to grow their income for 2 to 3 years before their rent increases.

• The other two most common administrative efficiency activities are more modest, increasing the value of assets that can be self-certified (14 PHAs) and eliminating utility reimbursements (11 PHAs).

• Another approved administrative efficiency activity that will likely save substantial staff time is less frequent Housing Quality Standard inspections (six PHAs), including one PHA with biennial inspections and five PHAs with some units that qualify for triennial inspections. Reducing the frequency of inspections could also increase landlord willingness to participate in the program.

Self-Sufficiency Objective. Of the 26 PHAs with an approved Supplement, 20 PHAs have approved MTW activities addressing the self-sufficiency objective, including 12 PHAs with several such activities. The most common approved activities are—

• Less frequent reexaminations for all households (13 PHAs), including 9 PHAs with biennial reexaminations and 4 PHAs with triennial reexaminations. In addition to saving administrative costs, this policy change is intended to encourage households to grow their incomes. 4

• Increasing the minimum rent (nine PHAs), including five PHAs that set the minimum rent at the MTW-waiver maximum of $130 and one PHA that set it at $127. A higher minimum rent is expected to encourage residents to increase earned income because the level at which

4 Other PHAs have less frequent reexaminations only for households on fixed incomes. Including those PHAs, 18 PHAs have less frequent reexaminations. Less frequent reexaminations and other activities are only counted as a self-sufficiency activity if the activity applies to nonelderly, nondisabled adults.

income affects rent is higher and some residents would need increased income to meet the rental obligation.

Other less frequent activities to encourage self-sufficiency that substantially change what a standard PHA can do include—

• A work requirement of at least 15 hours per week for nonelderly, nondisabled households (four PHAs).

• Mandatory MTW Self-Sufficiency program participation for nonelderly, nondisabled households (four PHAs).

• Financial incentives for meeting self-sufficiency goals (three PHAs), including one PHA paying a $500 bonus to households that continuously work full time for a year.

• A stepped rent (three PHAs) that can increase rent independent of an income increase. • A 5-year term limit for assistance, with 2 years of extension possible (one PHA).

Hardship exemptions accompanied many of these activities related to self-sufficiency. Some rent policy changes could also reduce the per-unit costs of housing assistance, potentially enabling PHAs to serve additional households.

Housing Choice Objective. Of the 26 PHAs with approved MTW Supplements, 19 PHAs have approved MTW activities that address the housing choice objective by either incentivizing landlords to participate or expanding the number of units available for voucher holders in the HCV program. The most commonly approved activities include—

• Financial incentives (10 PHAs) that range from $250 to $1,000 for a new landlord or an existing landlord renting a new unit with 2 PHAs offering $250 or $500 bonuses for referring new landlords to the HCV program. 5

• A payment standard of 120 percent of Fair Market Rent (FMR; eight PHAs)—a higher payment standard than the maximum 110 percent of FMR permitted for standard PHAs. A higher payment standard expands the number of units available to voucher holders without increasing the tenant-paid portion of the rent. A higher payment standard also usually means that the PHA can serve fewer households in its HCV program—a tradeoff that all PHAs must make.

Other Nonstandard Activities. Nine PHAs have approved waivers to do nonstandard activities through short-term assistance or the LNT activities waiver categories. These waivers allow PHAs to serve either their own assisted households or other low-income households in their community separate from the standard public housing and HCV programs. Five of the PHAs approved for LNT activities seek to expand the pool of affordable housing in their community. Three PHAs have waivers to provide self-sufficiency services not otherwise permitted for non-MTW PHAs. Examples of the planned activities are—

• Supporting development of supportive housing for youth aging out of foster care.

5 Two PHAs offer bonuses to new landlords of up to 1 month of contract rent, which could exceed $1,000. • Making improvements to a PHA-owned building and adding project-based vouchers to the site.

• Providing support for eight occupants of a transitional housing facility. • Providing 12 months of emergency assistance to households experiencing homelessness.

Changes Over Time. As part of the MTW-designation application process, MTW Flexibility Cohort PHAs submitted a 5-year vision for how they would use MTW flexibility. In Year 2 of MTW designation, PHAs continue to wait until later years to implement the full suite of waivers they eventually hope to implement. Reasons for not implementing everything at once include needing to understand how initial changes work in practice, updating software and reporting systems to support these changes fully, and addressing staff turnover disruptions. Some PHAs may no longer plan to seek all the waivers included in their 5-year plan because of leadership changes or rethinking. Similar to Year 1 of MTW designation, PHAs often highlight the importance of starting slowly to maintain a manageable amount of change for PHA staff and residents. Although these PHAs may still be interested in implementing more complex changes, such as LNT programs or work requirements, they plan to wait until later years to pursue these activities.

Implementation Status. Although 26 PHAs had approved MTW Supplements during the Year 2 analysis period, not all PHAs have begun implementing approved MTW activities. PHAs also implemented their approved activities at different times rather than all at once. Only seven PHAs had at least one MTW activity operating for at least 6 months in 2022, the year in which impacts from MTW activities are measured in this report. This implementation timing is important because activities likely must be in place for some time before effects are observed. In early 2023 interviews with PHA staff, 10 additional PHAs reported that they had started implementing activities in the second half of 2022 and 5 more PHAs started in the first quarter of 2023. This timing means that 22 Flexibility Cohort PHAs will have implemented at least one activity for all or most of 2023.

What are the Impacts of Moving to Work Flexibility on Smaller Public Housing Agencies and Their Residents?

As of this Year 2 (2022) impact analysis using a randomized experimental design, the offer to apply for MTW designation did not lead to statistically significant impact on cost-effectiveness but did lead to statistically significant impacts on self-sufficiency and housing choice. In 2022, the average annual earnings of nondisabled, nonelderly households were $2,478 higher in Treatment PHAs than in Control PHAs, and HCV households in Treatment PHAs were 2 percentage points more likely to reside in low-poverty census tracts than those in Control PHAs. Impact findings in future years will reveal whether these effects persist, with evidence about whether the Year 2 findings are simply spurious or truly associated with MTW activities.

Some indications show that these early findings could be due to chance. When comparing the outcomes of the Treatment PHAs with the larger pool of 99 Comparison PHAs (selected based on their similarity in baseline characteristics to Treatment PHAs) in the quasi-experimental analysis, statistically significant differences in self-sufficiency and housing choice outcomes were no longer observed. Furthermore, although many Treatment PHAs were approved to implement activities, few had started implementing them in 2022. The impact evaluation is slated to continue for 2 more years. Additional Flexibility Cohort PHAs will begin implementing their approved MTW activities in 2023 and 2024, and MTW PHAs that have already started will implement more activities. Thus, program impacts estimated in future evaluations will reflect a fuller implementation as more PHAs will have implemented MTW Waivers and associated activities for longer durations.

1. Introduction

Moving to Work (MTW) is a HUD demonstration program that gives public housing agencies (PHAs) statutory and regulatory flexibility to test ways to achieve the program’s three statutory objectives of increasing the cost-effectiveness of federal housing programs, encouraging greater self-sufficiency of households receiving housing assistance, and increasing housing choices for low-income families. In addition to statutory and regulatory flexibility around practices and policies, MTW PHAs also get funding flexibility, letting them use their allocated funding for the Housing Choice Voucher (HCV) and public housing programs for any allowable use under either program and for local, nontraditional (LNT) activities.

The MTW Demonstration Program was authorized by Congress under Section 204 of the Omnibus Consolidated Rescissions and Appropriations Act of 1996. 6 In 2016, Congress directed HUD to expand the MTW Demonstration Program by 100 PHAs and required HUD to set aside 50 slots for smaller PHAs, defined as agencies administering 1,000 or fewer combined HCV and public housing units. At that time, 39 PHAs already had MTW designation, and only 1 had fewer than 1,000 units. HUD is adding the 100 new MTW PHAs to the demonstration program in cohorts, with each cohort testing a different policy change. 7

The first cohort of the MTW expansion—the subject of this report—is limited to smaller, high-performing PHAs under the Public Housing Assessment System (PHAS) or the Section 8 Management Assessment Program at selection (and not “troubled” under either). 8 For this cohort, HUD determined that the MTW policy focus would be to observe how smaller PHAs choose to use the full array of MTW flexibilities and how these flexibilities affect PHAs and assisted households. This cohort tests the overall impact of MTW flexibility at smaller PHAs and is referred to as the “Flexibility Cohort.” 1.1 Content of This Report

The Year 2 Annual Report covers the planning and implementation of the Flexibility Cohort MTW activities in the second year (2022) after being offered the opportunity to become an MTW agency in January 2021. It details the early use of MTW flexibility in PHAs and estimates the short-term impact of MTW on PHA outcomes and assisted household outcomes. The evaluation of this first cohort is scheduled to continue for another 2 years, documenting how smaller PHAs use their MTW flexibility as they gain experience with the program and evaluating longer-term program impacts.

The rest of this chapter provides an overview of the evaluation design and explains the status of the Flexibility Cohort PHAs at the end of March 2023.

Chapter 2 describes the challenges that PHAs face in developing MTW Supplements and looks across PHAs to detail how many have received approved MTW Waivers in each category and the specific activities approved in that category. It concludes with PHA-reported lessons learned and recommendations on planning MTW activities.

6 Public Law 104-134, 110 Stat 1321. Section 239 of the Consolidated Appropriations Act, 2016 (Public Law 114-113). 7

8 For more information about PHAS, see https://www.hudexchange.info/sites/onecpd/assets/File/PHA-Lead-the-Way-Understanding-PHAS.pdf . For more information about the Section 8 Management Assessment Program, see https://www.hud.gov/program_offices/public_indian_housing/programs/hcv/semap .

Chapter 3 discusses how individual Flexibility Cohort PHAs combine MTW Waivers and associated activities to meet one or more of the three MTW statutory objectives.

Chapter 4 describes how Flexibility Cohort PHA plans for MTW Waivers have changed since their MTW application and summarizes recent legislation that provides additional flexibility for PHAs, even if they are not an MTW PHA.

Chapter 5 presents impact estimates of MTW flexibility for the PHAs in the second year after being offered the opportunity to become an MTW PHA. The outcomes are grouped by the three statutory objectives of the program: cost-effectiveness, self-sufficiency, and housing choice. The chapter focuses on the three confirmatory outcomes of the study—the outcomes judged to be the best single measures of whether the PHAs offered MTW flexibility have achieved each statutory objective. Chapter 5 briefly mentions exploratory outcomes, providing a more complete picture of the potential impact of MTW. 9

Chapter 6 discusses the findings of the process study and impact study research questions for the Flexibility Cohort in the second year after being offered the opportunity to become an MTW agency. 1.2 Evaluation Design and Data Sources

This evaluation aims to answer two questions.

• How do smaller PHAs use their MTW flexibility? How does MTW flexibility impact smaller PHAs and their residents? •

The evaluation of the Flexibility Cohort includes both a process and an impact study to address these questions. This chapter provides a brief overview of the study samples, process study, impact study, and data sources. Research Design / Data Collection and Analysis Plan and Evaluating MTW Flexibility for Smaller PHAs: Baseline Report provide more details on these topics (Geyer et al., 2023; Turnham et al., 2021). 1.2.1 Study Sample

HUD released a selection notice for the Flexibility Cohort in October 2018. Forty-three PHAs completed the initial letter of interest process from 2018 to 2019 and met the eligibility requirements for this first PHA expansion cohort.

HUD randomly assigned the 43 PHAs to either a treatment group (33 PHAs) or a control group (10 PHAs). The 33 Treatment PHAs were invited to apply for MTW designation. The 10 Control PHAs were not offered the opportunity to apply for MTW designation under the first cohort but were offered the opportunity to apply to future cohorts.

By the close of the application period, 31 of the 33 Treatment PHAs had submitted their MTW applications to HUD. In January 2021, HUD offered MTW designation to these 31 PHAs, forming the Flexibility Cohort.

9 See appendix C for a more comprehensive picture of the impact analysis on exploratory outcomes.

A balance test comparing the baseline characteristics of the 33 Treatment and 10 Control PHAs found that the PHAs were similar in almost every observable characteristic. 10 Overall, the 43 PHAs in the combined Treatment and Control sample had the following characteristics—

• The average PHA size was 525 combined units (public housing and HCV units), with approximately one-fifth (20.9 percent) of the PHAs having fewer than 250 units.

• About half (51.2 percent) of PHAs operated both public housing and HCV programs; more than one-third (37.2 percent) operated only an HCV program. A small share (11.6 percent) operated only a public housing program.

• Slightly more than 30 percent of PHA headquarters were in nonmetropolitan areas.

Exhibit A-1 lists the 31 Flexibility Cohort PHAs and shows their locations, sizes, and whether in a metropolitan area designation. Exhibit A-2 shows the same information for the 10 Control PHAs. 1.2.2 Process Study

The process study documents how smaller PHAs use their MTW flexibility. It focuses on the 31 Flexibility Cohort PHAs—their status as of the end of March 2023 and the challenges that they faced in completing the administrative steps needed to move forward with MTW flexibility.

The first step to obtain the flexibility that the MTW program allows is to fully execute an MTW Annual Contributions Contract (ACC) Amendment, officially designating a PHA as an MTW agency and allowing the PHA to use MTW funding flexibility. The second step is to complete the MTW Supplement to the PHA Annual Plan. In the Supplement, the PHAs describe their MTW activities planned for the coming year that require MTW Waivers. HUD must approve their MTW Supplement before the PHAs may implement those activities.

The Year 2 Annual Report highlights MTW activities of the Flexibility Cohort PHAs in 2022— the second year after being offered the opportunity to become an MTW PHA and the first full year when most of these PHAs were officially an MTW PHA. It addresses the first research question about how smaller PHAs use MTW flexibility. It also reports information from Control PHAs about MTW-like activities undertaken in their standard program. 1.2.3 Impact Study

The main goal of the impact study is to estimate the effects on the three statutory objectives of MTW flexibility granted to smaller PHAs.

The experimental analysis in this report compares the average of the 33 Treatment PHAs randomly assigned to the treatment group versus the average of the 10 Control PHAs randomly assigned to the control group for the outcomes of interest, based on calendar year 2022 data. This analysis assesses the impact of the opportunity to apply for MTW flexibility on outcomes that represent the statutory objectives of cost-effectiveness, self-sufficiency, and housing choice. Randomly assigning PHAs to treatment and control groups ensures that no systematic

10 Turnham et al. (2021) found that only 1 of the 20 characteristics compared was statistically significantly different

at baseline, fewer households at the Treatment PHAs than at Control PHAs were using Special Purpose Vouchers (5.3 compared with 13.7 percent). Geyer et al. (2023) found that Treatment and Control PHAs were also very similar in the planned activities stated in their initial MTW applications.

differences between the groups exist, except by chance. Thus, the impact analysis with this randomized design yields unbiased estimates of the overall effect of the opportunity to apply for MTW designation on the MTW statutory objectives among smaller PHAs. 11 1.2.4 Data Sources

The process study findings in this report are based on PHA staff interviews and MTW Supplements. The impact study outcome measures are based on HUD administrative data and other secondary data sources. • Interview data collected for the evaluation include—

o Information from PHA staff interviews with 30 of the 31 Flexibility Cohort PHAs on the MTW onboarding process and planned MTW activities. o Interviews were conducted between February and March 2023. Only 1 of the 31 Flexibility Cohort PHAs could not complete an interview during this timeframe.

• HUD administrative data for calendar year 2022 include—

o Data on neighborhood locations and program exits of public housing residents and voucher households from the HUD Inventory Management System/Public and Indian Housing Information Center. PHA cost data from the Financial Data Schedule. o o PHA voucher lease and budget data from the Voucher Management System. o Public housing development inspection scores from the HUD Real Estate Assessment Center.

• Data from the MTW Supplements for the 26 Flexibility Cohort PHAs with approved supplements by the end of March 2023. • Other data sources include—

o Earnings data from the National Directory of New Hires.12 o Data on neighborhood poverty rates, income, and rents from the American Community Survey (ACS). 13

11 During the research design phase of this evaluation in 2020, HUD and the evaluation team recognized that the small size of the control group ( n = 10) limits the ability to analyze the impact of MTW for certain types of PHAs (such as those with only voucher programs). To supplement the future findings of the impact study experimental

analysis, the evaluation team selected a matched group of 99 Comparison PHAs, similar in observable baseline characteristics to the Treatment PHAs, to add a quasi-experimental analysis. This Year 2 Annual Report does not present detailed results for the quasi-experimental analysis, but chapter 5 uses the results of the quasi-experimental analysis to help judge the reliability of the impact estimates generated by the experimental analysis.

12 Maintained by the federal Office of Child Support Services, the National Directory of New Hires database include quarterly earnings measured by state Unemployment Insurance systems and earnings of federal, civilian, and military employees provided by various federal agencies More information is available at https://www.acf.hhs.gov/css/training-technical-assistance/guide-national-directory-new-hires .

13 ACS is an annual survey of more than 3 million residents that asks about household income, occupation, and housing situation. ACS 5-year estimates are available for calculating census tract-level information such as average rents, income, and poverty rate. More information is available at https://www.census.gov/programs-surveys/acs/ . 1.3 Status of Flexibility Cohort Moving to Work Public Housing Agencies

HUD announced the 31 Flexibility Cohort PHAs in January 2021. By February 2022, all 31 PHAs had fully executed an MTW ACC Amendment. An MTW PHA is not designated until the PHA fully executes this amendment to its ACC, the vehicle through which HUD provides funds for the HCV and public housing programs. Once the MTW ACC Amendment is in place, a PHA funding flexibility starts the following month. MTW funding flexibility allows PHAs to use funds across the four funding streams for any activities allowed under the public housing and HCV programs, for LNT activities, or other approved MTW Waivers. The funding streams that may be used flexibly are (1) public housing Operating Fund grants, (2) public housing Capital Fund grants, (3) HCV Housing Assistance Payment (HAP) funds, and (4) HCV administrative fee funds.

Implementing any activities that require MTW Waivers takes another step beyond the MTW ACC Amendment. The PHA must complete (and receive HUD approval of) the MTW Supplement to the PHA Annual Plan, describing its plans for the fiscal year. Exhibit 1-1 shows the timing of each of the first approved MTW Supplement for Flexibility Cohort PHAs. Three PHAs had their first approved MTW Supplement in September 2021, and two more PHAs had approved MTW Supplements by the end of 2021. By the end of 2022, 26 of the 31 Flexibility Cohort PHAs had approved MTW Supplements, allowing them to start implementing MTW activities. Exhibit 1-1. Timing of First Approved Moving to Work Supplement as of March 31, 2023

PHAs = public housing agencies. Notes: Some Moving to Work (MTW) PHAs have had more than one MTW Supplement approved, but only the timing of the first approval is shown. Five of the 31 Flexibility Cohort PHAs did not have an approved MTW Supplement as of March 31, 2023. The endpoint of the graph is March 2023, when the evaluation team completed Year 2 interviews of Flexibility Cohort PHAs. Source: Participating agencies are listed here

https://www.hud.gov/program_offices/public_indian_housing/programs/ph/mtw/mtwagencies

The impact analysis uses outcomes measured during calendar year 2022. The timing of the fully executed ACC Amendments and first approved MTW Supplements indicates that most of the

Flexibility Cohort PHAs had a full year of funding flexibility.14 In addition, five PHAs had approved MTW Supplements in 2021, meaning they had all 2022 to implement and observe impacts from activities that the MTW Waivers allowed. Another eight PHAs had MTW Supplements approved by June 2022, thus having at least 6 months for their MTW activities to be effective. It is unlikely that program impacts can be observed given that less than half (13) of the PHAs in the treatment group (33) had approved MTW Waivers for at least 6 months. As chapter 2 discusses, it usually takes PHAs a few months after approval to implement activities, meaning even less time for MTW to have had an impact in 2022 (see chapter 5 for interim impact estimates).

14 The two PHAs that did not have an executed ACC Amendment in 2021 had one by February 2022 and, thus, had funding flexibility for most of the year. 2. Moving to Work Supplement Process and Approved Waivers Across Public Housing Agencies

Moving to Work (MTW) expansion public housing agencies (PHAs) are required to submit an MTW Supplement to their PHA Annual Plan to HUD annually, at least 75 days before the start of their fiscal year. The MTW Supplement describes the MTW Waivers and associated activities that the PHA seeks approval to implement during the upcoming fiscal year, including any activities approved in a previous MTW Supplement. The MTW Supplement must be reviewed and approved by the HUD field office before the PHA can begin any new MTW activities.

This chapter reviews the MTW Supplement process for Flexibility Cohort PHAs and discusses the program changes they chose to implement with MTW flexibility. Appendix B provides a detailed description of which MTW activities each PHA with an approved MTW Supplement is authorized to implement as of the end of March 2023 and background information on the PHA, including which types of programs it operates.

This chapter is based on information that PHAs provided in their approved MTW Supplements and during interviews with staff from 30 of the 31 Flexibility Cohort PHAs. 15 The interviews were conducted from February through March 2023 and covered PHA activities during 2022 and early 2023. 2.1 Overview of the Moving to Work Supplement Process

The MTW expansion PHAs are subject to the MTW Operations Notice (HUD, 2020), which provides a preapproved menu of 70 MTW Waivers and associated MTW activities that need documenting in their yearly MTW Supplement before implementation. 16 The MTW Operations Notice groups the MTW Waivers in 17 categories (exhibit 2-1). PHAs may also request that HUD review agency-specific waivers not covered under the menu of preapproved waivers. Exhibit 2-1. Categories of Moving to Work Preapproved Waivers

15 One PHA declined to participate in an interview with the evaluation team and did not have an approved MTW

Supplement as of the end of March 2023. This PHA is not included in the analyses reported in this chapter. 16 The MTW Operations Notice can be found at https://www.hud.gov/sites/dfiles/PIH/documents/FinalMTWExOpsNoticePartVIWeb.pdf .

1. Tenant Rent Policies allow public housing agencies (PHAs) to create stepped rents based on incremental increases in rent at predetermined times, implement tiered rents tied to income bands, or set fixed rents or subsidies. Moving to

Work (MTW) Waivers and associated MTW activities in this category also allow for PHAs to increase the minimum rent up to $130, change the tenant rent payment to be a percentage of adjusted household income, create an alternative utility allowance schedule, eliminate utility reimbursements when greater than the total tenant payment, change tenants’ allowable rent burden (housing choice voucher [HCV]), impute income based on hours worked per week, eliminate deductions, institute a single standard deduction, or set alternative inclusions or exclusions in the income used to calculate rent.

2. Payment Standards and Rent Reasonableness allow PHAs to increase the payment standard to reflect a different percentage of the Fair Market Rent or Small Area Fair Market Rent; conduct rent reasonableness tests for units the

PHA owns, manages, or controls rather than outsourcing this activity to a third party; and develop a local process for determining rent reasonableness that differs from traditional program requirements.

3. Reexaminations allow tenants to self-certify their assets up to $50,000 and PHAs to change the tenant reexamination schedule to permit biennial or triennial reexaminations.

4. Landlord Leasing Incentives allow PHAs to pay tenant damage claims to landlords, offer vacancy loss payments, or provide other landlord incentives, such as signing bonuses.

5. Housing Quality Standards allow PHAs to conduct inspections for units that PHAs own, manage, or control rather than hire a third party; change inspection schedules; offer prequalifying inspections to landlords before tenants are identified; and levy penalties on landlords that fail inspections.

6. Short-Term Assistance allows PHAs to offer short-term housing assistance for specific populations, such as people experiencing homelessness.

7. Term-Limited Assistance allows PHAs to limit the length of housing assistance to specific timeframes no less than 4 years.

8. Increase in Elderly Age allows PHAs to raise the age at which a head of household is considered elderly from 62 to 65. 9. Project-Based Voucher (PBV) Program Flexibility allows PHAs to limit portability for PBVs, increase rent payments

to owners beyond the HCV payment standard, extend the length of PBV contracts, expand the types of housing that qualify for PBVs, increase the total number of PBVs a PHA can offer, increase the cap on the number of PBVs that can be in one housing development, and change the selection process for PBV units.

10. Family Self-Sufficiency (FSS) Program with MTW Flexibility allows PHAs to change how increases in family income affect rent, escrow or savings, use alternative selection criteria for families entering the program, change the program coordinating committee, eliminate or change a family’s Contract of Participation, or entirely waive operating a required FSS program.

11. MTW Self-Sufficiency Program allows PHAs to set new policies for handling increases in family income that affect rent or savings and gives PHAs the ability to use alternative selection criteria for families entering existing or

successor (non-FSS) self-sufficiency or training programs that a PHA operates.

12. Work Requirements allow PHAs to implement work requirements as a condition for program participation—up to 15

hours per week for nonelderly, nondisabled adults or 30 hours for qualifying households.

13. Public Housing as an Incentive for Economic Progress provides the ability to allow households above income thresholds to retain housing assistance for longer periods.

14. Moving-On Policy allows PHAs to align rent and utility payments with partner agencies, accept income calculations from partner agencies, and waive initial housing quality standards inspection for households transitioning out of permanent supportive housing.

15. Acquisition Without Prior HUD Approval provides flexibility in the timeline for HUD approval when acquiring a new site.

16. Deconcentration of Poverty in Public Housing allows PHAs to create their own policy to address the deconcentration of poverty in public housing.

17. Local, Nontraditional Activities allow PHAs to adopt unique localized programs to develop new housing units, provide resident services, or provide alternative rental subsidy programs.

Source: Moving to Work Operations Notice, https://www.hud.gov/sites/dfiles/PIH/documents/FinalMTWExOpsNoticePartVIWeb.pdf

As MTW Supplements are received, the HUD MTW Office and the PHA’s local HUD field office review, and either approve or provide feedback on the PHAs’ planned use of MTW Waivers and associated MTW activities. If their MTW Supplement is not initially approved, PHAs may revise and resubmit an updated MTW Supplement for further review. Once approved, PHAs can implement the MTW activities described in their MTW Supplement. PHAs repeat this process annually to receive continuing approval to implement previously approved MTW Waivers and associated MTW activities; request approval for any new MTW Waivers and associated MTW activities they plan to implement; and provide information that allows HUD to monitor and evaluate their program.

As of March 31, 2023, 26 of the 31 Flexibility Cohort PHAs had at least one approved MTW Supplement, meaning they were authorized to implement the MTW Waivers and associated activities described in their MTW Supplement. The other five PHAs did not have an approved MTW Supplement as of March 31, 2023. Without an approved MTW Supplement, these five PHAs could use MTW funding flexibility but could not implement any adjustments to their public housing or HCV programs outside of the regular program rules and regulations or waivers previously granted by HUD outside of the MTW Demonstration Program.

Only one of the five PHAs without an approved MTW Supplement, Fayetteville Housing Authority, has yet to begin working on its first MTW Supplement. Fayetteville Housing Authority experienced significant staff turnover since receiving MTW designation and recently hired a new Executive Director in November 2022. The timeline for moving forward with the Fayetteville MTW Supplement was still under discussion at the time of data collection. 2.2 Public Housing Agency Experiences Completing the Moving to Work Supplement

The process to complete the MTW Supplement requires review and input from PHA staff, approval by the PHA Board of Commissioners or equivalent body, and a public comment process, during which residents and other parties can weigh in on the proposed MTW-related activities by the PHA. As of March 2023, 30 of the 31 PHAs in the Flexibility Cohort had either begun or completed the process to submit the MTW Supplement, including 5 PHAs having had two MTW Supplements approved. 17 Additional PHAs had begun working on their second MTW Supplements at the time of their interview; thus, these PHAs have had the opportunity to think about which MTW Waivers and associated activities to add, remove, or revise after beginning to implement MTW activities.

Most PHAs that had worked on a second MTW Supplement reported that the overall process was easier the second time. Completing the second MTW Supplement usually required only minor adjustments to the first MTW Supplement before going through the public comment and HUD review process again. For example, one PHA said that hiring an external consultant to help work through the first MTW Supplement was instrumental to getting the task done. However, the

17 At least one PHA was preparing its third MTW Supplement. consultant was no longer needed to complete the second MTW Supplement because the PHA already had the groundwork laid from which to build.

PHAs generally reported feeling that the training provided by HUD left them prepared to complete their MTW Supplement, yet still reported facing numerous challenges in gaining approval. The most common challenges for PHAs, for either their first or their second MTW Supplement, were —

• Delays in the HUD Review and Approval Process. PHAs reported significant delays in the MTW Supplement review process. For example, a few PHAs said that by the time their first MTW Supplement was approved, it was only a few weeks or months before they needed to submit their MTW Supplement for the next fiscal year. Some PHAs attributed this delay to staff turnover at the HUD field office or the field office not being fully read into the MTW Demonstration Program expansion.

• Inconsistencies in the HUD Review Process. One PHA said staff turnover at the HUD field office resulted in inconsistent and conflicting guidance on completing the MTW Supplement. Another PHA said the HUD review process and criteria differed for the second MTW Supplement. For example, HUD returned the second MTW Supplement from a PHA requesting additional detail, even though the PHA had used the same level of detail that it did in its first approved MTW Supplement.

• Limitations of PHA Staff. PHAs reported that the MTW Supplement process could be cumbersome. It could be challenging for a smaller PHA to complete all required steps and impact analyses because their workloads were already at or over capacity. Completing the impact analyses and ensuring that the PHA retrieved the correct or similar data were also challenging for PHAs where staff turnover had occurred since completing the first MTW Supplement. At one PHA, the current MTW coordinator had taken over the position from a former staff member who did not share documentation on extracting data for the figures in the impact analysis. Therefore, trying to recreate those figures for the second impact analysis was time intensive. Similarly, among PHAs with staff turnover in the MTW role, getting up to speed on the submission process was time-consuming. Some staff said finding the most relevant training resources on the HUD website could be challenging.

• Challenges with Technology. PHAs experienced technological issues with the online MTW Supplement form, such as being unable to print a copy of the submission, making it hard to proofread. Moreover, one PHA said the printed copy of the form did not display changes made in the online form. Issues with the user interface were also reported, such as not allowing users to save a draft of the MTW Supplement unless an entire section was complete. The system also did not have a “back” or “previous” button after the first two pages, which meant the user could not go back to edit or copy and paste similar content from a previous section.

• Difficulty Getting Agency-Specific Waivers Approved. One PHA expressed frustration about difficulties in getting agency-specific waivers approved. The PHA had gone through multiple rounds of back-and-forth with HUD on the waivers, and the PHA eventually agreed to remove them from its MTW Supplement because getting the agency-specific waivers approved was taking too much time. In light of these challenges, PHAs recommended that HUD offer more interactive, ongoing training—especially for new staff—that sets aside enough time for questions and answers or allows questions via a chat feature. New staff said a step-by-step process checklist would help orient them to the MTW Supplement submission requirements and timeline. Some Flexibility Cohort PHAs formed self-directed collaboratives to help one another navigate the MTW process. 2.3 Approved Moving to Work Waivers and Activities Across Public Housing Agencies

This section describes the MTW Waivers and associated activities selected by the 26 PHAs with approved MTW Supplements as of March 31, 2023. 18 The section begins with an overall description of approved activities in each waiver category described in the MTW Operations Notice (exhibit 2-2), the goals for PHAs using the waivers, and the anticipated costs and outcomes for common waivers. Exhibit 2-3 explains when MTW Waivers apply to Special Purpose Vouchers (SPVs). For specific information about the waivers and activities each PHA is approved to implement, see appendix B. Exhibit 2-2. MTW Waivers Selected by the 26 PHAs With Approved MTW Supplements

01. Tenant Rent Policies 21

02. Payment Standards and Rent Reasonableness 13

03. Reexaminations 21

04. Landlord Leasing Incentives 10

05. Housing Quality Standards 12

06. Short-Term Assistance 1

07. Term-Limited Assistance 1

08. Increase in Elderly Age 0

09. Project-Based Voucher Program Flexibilities 7

10. Family Self-Sufficiency Program with MTW Flexibility 7

11. MTW Self-Sufficiency Program 5

12. Work Requirements 4

13. Public Housing as an Incentive for Economic Progress 1

14. Moving-On Policy 0

15. Acquisition Without Prior HUD Approval 2

16. Deconcentration of Poverty in Public Housing 0

17. Local, Non-Traditional Activities 7

Agency-Specific Waiver 1

0 5 10 15 20 25

Number of PHAs with at Least One Approved Waiver in the Category

MTW = Moving to Work. PHA = public housing agency.

Notes: See appendix I of the Operations Notice for more information on these waivers (HUD, 2020), which are numbered in the exhibit to align with their number in the Operations Notice. Of the 31 Flexibility Cohort PHAs, 26 had an MTW Supplement approved as of March 31, 2023. Of these 26 PHAs, 13 operate both public housing and Housing Choice Voucher (HCV) programs, 10 operate only an HCV program, and 3 operate only a public housing

18 Section 2.5 describes and compares the planned activities for PHAs without an approved MTW Supplement. program. Some of the waivers represented have multiple activities that fall under that waiver. The exhibit aggregates them so that any PHA approved to implement one or more of the activities under a waiver category is represented only once per category. Sources: MTW Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements

Exhibit 2-3. Applying Moving to Work Flexibility to Special Purpose Vouchers

In addition to providing housing assistance through the public housing and Housing Choice Voucher (HCV) programs, some public housing agencies (PHAs) receive funding to provide Special Purpose Vouchers (SPVs). SPVs are distinct from regular HCVs and are usually designated to serve specific populations. Examples of SPVs include—

• Emergency Housing Vouchers (EHVs), which are provided based on a memorandum of understanding between the PHA and the local Continuum of Care to households currently experiencing or at risk of experiencing homelessness, fleeing or attempting to flee a domestic violence (or similar) situation, or having recently experienced homelessness or a

high risk of housing instability.

• Family Unification Program (FUP) vouchers, which are provided to (1) youth aged 18–24 who left foster care at age 16 or older and are experiencing or at risk of experiencing homelessness, and (2) families for whom a lack of adequate housing will result either in the placement of their child(ren) in out-of-home care or a delay in discharging their child(ren)

from out-of-home care.

• Foster Youth to Independence (FYI) vouchers, which are provided to youth aged 18–23 who have left or will leave foster care within 90 days and are experiencing or at risk of experiencing homelessness.

• HCV Community Choice demonstration vouchers, which are provided to families with children and include mobility services to help families access housing in opportunity (typically low-poverty) areas.

• HUD-Veterans Affairs Supportive Housing (VASH) vouchers, which provide housing, case management, and clinical services to veterans experiencing homelessness.

• Mainstream vouchers, which provide assisted housing to families with at least one member aged 18–61 who has a disability.

• Nonelderly Disabled (NED) vouchers, which provide assisted housing to families whose head of household, spouse, or co-head of household is younger than the age of 62 and has a disability.

SPV funding cannot be used as a part of MTW funding flexibility; however, all Moving to Work (MTW) Waivers and associated activities included in an approved MTW Supplement can be applied to SVPs without seeking HUD approval, with two exceptions. First, MTW Waivers and activities cannot be applied to FUP, FYI, HCV Community Choice

demonstration, Mainstream, or NED vouchers if the MTW-related changes are inconsistent with the 2016 Consolidated Appropriations Act that authorized the MTW expansion or requirements of the Notice of Funding Availability for the SPV program. Second, MTW Waivers and activities cannot be applied to EHV or HUD-VASH vouchers if the MTW-related changes conflict with the authorizing language or other HUD-VASH or EHV operating requirements; however, if a conflict exists and the PHA would still like to apply the MTW flexibilities, the PHA may submit a request to its local HUD field office to apply the MTW flexibilities to the HUD-VASH or EHV vouchers.

Of the 26 Flexibility Cohort PHAs, 19 said they operate SPVs. Among these PHAs, 13 said they planned to extend or had already begun extending MTW Waivers and associated activities to at least some of their SPVs. PHAs that chose not to apply MTW Waivers and activities to their SPVs did so because either the waivers being implemented would not apply to

residents served with the SPVs (that is, elderly and disabled residents exempt from the MTW-related activities) or the populations served by the SPVs were seen as vulnerable, and the primary goal for serving those populations was stabilizing their living situation.

Notes: Tenant Protection Vouchers (TPV) are a type of HCV designed to prevent hardship as the result of a conversion of a PHA public housing property, Multifamily Housing portfolio, or Moderate Rehabilitation property. TPVs are not considered SPVs, but similar policies for applying MTW flexibility to TPVs exist. According to HUD guidance, MTW PHAs may apply funding flexibility “to replacement TPV funds (including enhanced vouchers, set-aside TPVs, and regular TPVs funded as replacement TPVs) once the initial funding increment is renewed but not during the initial funding increment.” MTW flexibility cannot be applied to relocation TPVs. MTW Waivers and associated activities may be applied to TPVs only if the actions do not infringe on the protections TPVs grant. Sources: MTW Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements; MTW and SPV Frequently Asked Questions,

https://www.hud.gov/sites/dfiles/PIH/documents/SpecialPurposeVouchersFAQ.pdf; communications with HUD

Changes to tenant rent policies and the reexamination process continued to be the most common activities for which PHAs requested approval. More than 80 percent of PHAs with approved MTW Supplements are approved for one or both waivers. Implementing payment standards and rent reasonableness waivers was also a popular change, selected by 50 percent of PHAs with an approved MTW Supplement. 2.3.1 Tenant Rent Policies

Twenty-one PHAs are authorized to implement changes to their tenant rent policies. Exhibit 2-4 lists the types of tenant rent policy adjustments these PHAs are approved to implement and how many PHAs are approved to implement each specific activity. Exhibit 2-4. Approved Activities to Adjust Tenant Rent Policies

Tenant Rent Policy Activity # of PHAs Approved to Use MTW Activity ( n = 21)

Utility Reimbursements 11

Minimum Rent 10

Alternative Utility Allowance 9

Elimination of Deduction(s) 8

Alternative Income Inclusions or Exclusions 8

Initial Rent Burden 5

Tenant Payment as a Modified Percentage of Income 4

Standard Deductions 3

Stepped Rent 3

MTW = Moving to Work. PHA = public housing agency. Notes: Of the 31 Flexibility Cohort PHAs, 26 had an MTW Supplement approved as of March 31, 2023. Of these 26 PHAs, 13 operate both public housing and HCV programs, 10 operate only a Housing Choice Voucher (HCV) program, and 3 operate only a public housing program. HUD divides tenant rent policy waivers between public housing residents and HCV residents. The exhibit aggregates them so that any PHA approved to implement one or more activities under the tenant rent policy waiver category is represented only once per category. Activities for which no PHA has approval are not listed. Sources: MTW Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements

Among the 21 PHAs approved to implement changes to their tenant rent policies, the approved changes include—

• Utility Reimbursements. This activity allows PHAs to eliminate utility reimbursements when the utility allowance is greater than the total tenant payment —the amount of rent a public housing or HCV resident is responsible for paying. PHAs tended to implement utility reimbursements for one of two reasons. The first reason was administrative. PHAs were sending out reimbursement checks, sometimes for only a few dollars, and the checks often went uncashed by residents. The administrative work to write, mail, track, reissue, or cancel the reimbursement checks was time consuming and did not return notable benefits for the residents. The second reason was to encourage self-sufficiency. PHAs said that removing utility reimbursements would require residents to make enough income to pay at least some portion of rent. This activity has been cost-positive for PHAs, with expected savings of

$4,000 to $25,000 a year. This policy is generally limited to nonelderly and nondisabled or work-capable households and includes a hardship policy. 19

• Minimum Rent. Under this activity, PHAs can increase the minimum rent from what is allowed under current statutes and regulations (typically $25 to $50 a month) to as much as $130 a month. Half of the PHAs selecting this change (five PHAs) plan to or have already increased the minimum rent to $130, the maximum allowable amount under the waiver. PHAs selected this activity, sometimes in tandem with eliminating the utility reimbursement activity, to reduce the number of residents paying a “negative rent.” Negative rents happen when a resident receives more rental assistance from the PHA than they are required to pay in rent. The change is expected to support self-sufficiency by encouraging residents to work and acclimate them to paying a portion of their rent each month. Across all PHAs, this policy is limited to nonelderly and nondisabled households and includes a hardship policy.

• Initial Rent Burden. This activity allows PHAs to increase the initial limit on how much of a household’s monthly adjusted income can be put toward paying rent if rent is above the payment standard. 20 The waiver allows the maximum initial rent burden to increase from 40 percent of a household’s adjusted monthly income to as much as 60 percent. PHAs reported selecting this waiver to improve resident housing choice. HCV recipients had difficulty finding affordable rental units of the desired size or standards in high-cost rental markets. Since implementing this activity, some PHAs have reported increased voucher lease-up success rates, even when the initial rent burden cap increased to 45 or 50 percent rather than the full 60 percent allowed under the waiver.

• Tenant Payment as a Modified Percentage of Income. Under this activity, PHAs are allowed to modify the percentage of income used to calculate the resident total tenant payment (TTP)—the minimum amount a resident is required to pay for rent and utilities. Under standard program regulations, TTP must not exceed 30 percent of a household’s monthly adjusted income. 21 Under MTW, PHAs can decrease or increase this threshold. If increasing, the maximum TTP may be set at 32 or 35 percent of a household’s monthly adjusted income, depending on whether other adjustments to tenant rent policies are also approved for implementation. 22 Among the four PHAs approved to implement this activity,

19 Certain MTW Waivers require a hardship policy. Under the hardship policy, the PHA specifies who may be eligible for an exemption from the MTW activity and under what circumstances; for example, a household

experiencing a decrease in income or a considerable increase in expenses due to changed circumstances. 20 If a household selects to rent a unit where the rent is above the payment standard, the household must make up the difference between the payment standard and the gross rent. Under the maximum initial rent burden, the household cannot pay more than a set amount of the monthly adjusted income for rent when the household moves initially into

the rental unit or signs the first lease for the unit. The initial rent burden is composed of the portion of rent above the payment standard plus 30 percent of the household’s monthly adjusted income for rent up to the payment standard. 21 TTP is calculated as the greater of 30 percent of monthly adjusted income, 10 percent of monthly gross income, welfare rent from a public agency, or the PHA minimum rent. For this activity, the adjustments are made to the first

criterion on the list: 30 percent of monthly adjusted income. For more information on calculating TTP, see the HCV Program Guidebook to Calculating Rent and Housing Assistance Payments https://www.hud.gov/sites/dfiles/PIH/documents/HCV_Guidebook_Calculating_Rent_and_HAP_Payments.pdf . The waiver activity caps TTP at 32 percent of a household’s monthly adjusted income if the PHA also uses MTW 22

activities to change deductions, income inclusions, or exclusions. If the PHA uses waiver activities to adjust deductions, income inclusions, or exclusions, TTP can be increased to as much as 35 percent of a household’s monthly adjusted income.

three PHAs are using the waiver to decrease TTP from 30 to 27 or 28 percent of monthly adjusted income. PHAs are lowering TTP to reduce the financial burden on residents that other adjustments to tenant rent policies to alleviate PHA administrative burden may impose, such as eliminating deductions. Conversely, one PHA is increasing the TTP to 35 percent to encourage employment further and promote self-sufficiency. The TTP increase is also expected to lower Housing Assistance Payment (HAP) costs for that PHA, which can be reinvested to serve more households. Across all MTW PHAs, this policy is limited to nonelderly and nondisabled households and includes a hardship policy.

• Stepped Rent. A stepped rent model increases a household rent payment on a fixed schedule and by a fixed amount, regardless of household income changes. The shared goal among PHAs for implementing a stepped rent schedule is to promote self-sufficiency by gradually increasing a household’s share of rent until they can fully pay for their housing without a subsidy. Across all PHAs, this policy is limited to nonelderly and nondisabled households and includes a hardship policy. For details on how each PHA defined its stepped rent schedule, see the PHA profiles for Ruston Housing Authority (LA-054), Rockville Housing Enterprises (MD-007), and Robeson County Housing Authority (NC-084) in appendix B.

• Other Waivers. PHAs also selected the activities to set alternative utility allowances, eliminate deductions, establish alternative income inclusions or exclusions, and move to standard deductions to streamline the processes and increase staff capacity. PHAs said that maintaining multiple utility allowances that could vary based on unit type, size, and utility source was burdensome for staff and confused residents. To address this problem, PHAs opted to adopt streamlined utility allowances, such as one that only varies by bedroom size. Similarly, PHAs chose to eliminate certain deductions—such as medical or unreimbursed childcare expenses—because they often made rent calculations difficult and time intensive for PHA staff and burdened residents to keep track of expenses and receipts. Some residents frequently requested interim reexaminations if they recently had a large medical expense. Eliminating certain deductions or revising standard deductions is expected to free up PHA staff capacity and make the process easier for residents to understand. 2.3.2 Payment Standards and Rent Reasonableness

Thirteen PHAs are approved to implement activities to adjust the payment standards or rent reasonableness process. Payment standards represent the HUD-defined standard rent expected for a moderately priced rental unit and are typically set at 90 to 110 percent of the area’s Fair Market Rent (FMR). The rent reasonableness process validates that the rent charged to an HCV resident is comparable with similar rental units in the local market. Exhibit 2-5 lists the types of adjustments to payment standards and rent reasonableness the cohort PHAs are approved to implement and how many PHAs are approved to implement each specific activity. Exhibit 2-5. Approved Activities to Adjust Payment Standards and Rent Reasonableness

Payment Standards and Rent Reasonableness Activities # of PHAs Approved to Use MTW Activity ( n = 13)

Payment Standards—Fair Market Rents 9

Rent Reasonableness—Third-Party Requirement 4

Rent Reasonableness—Process 2

MTW = Moving to Work. PHA = public housing agency. Notes: Of the 31 Flexibility Cohort PHAs, 26 had an MTW Supplement approved as of March 31, 2023. Of these 26 PHAs, 13 operate both public housing and HCV programs, 10 operate only a Housing Choice Voucher (HCV) program, and 3 operate only a public housing program. Payment standards and rent reasonableness waivers apply only to HCV programs. Activities for which no PHA has approval are not listed. Sources: MTW Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements Among these 13 PHAs, the approved changes include—

• Payment Standards and Fair Market Rents. This activity allows PHAs to set payment standards between 80 and 120 percent of FMR. All but one of the PHAs approved for this activity opted to increase payment standards to 120 percent of FMR for at least some unit sizes. The other PHA increased payment standards from 100 to 110 percent of FMR. 23 PHAs selected this activity to make more units in the community affordable to HCV recipients, thus improving housing choice for residents. The need for higher payment standards was driven partly by general challenges in finding affordable units in areas with a high cost of living or an expensive rental market; however, some PHAs said that coming out of the COVID-19 pandemic, they saw landlords increase rents at a rate that did not match adjustments to FMRs. Raising the payment standards was one way for HCV recipients to compete with residents seeking units at market price. This activity increases costs for a PHA by increasing the PHA’s HAP for HCV residents. PHAs anticipated making up for the increase in cost through cost savings from other activities planned in combination with this change.

• Rent Reasonableness Third-Party Requirement. This activity allows a PHA to conduct the rent reasonableness process on project-based voucher (PBV) units that it owns, manages, or controls. PHAs opted to implement this waiver to build efficiency and streamline the process by allowing one party—typically the PHA—to conduct all rent reasonableness determinations, regardless of who owns the unit. This change saves the PHA time and money by not having to coordinate with and pay an external party to complete the task.

• Rent Reasonableness Process. Under this activity, PHAs can create a local process for determining rent reasonableness that differs from the mandated process. The local process must still have a way to determine if the rent charged for an HCV unit is comparable with similar units in the area. PHAs selected this activity to increase efficiency within the PHA or to simply formalize with HUD’s MTW Office their existing processes for determining rent reasonableness. The change is not expected to have a cost impact on either the PHAs or their residents. 2.3.3 Reexaminations

Twenty-one PHAs are approved to implement activities to adjust the reexamination process. Under both the public housing and the HCV program, residents must complete reexaminations to verify their continued eligibility for the program. Exhibit 2-6 lists the changes PHAs are approved to implement and how many PHAs are approved to implement each specific activity.

23 This waiver was approved as part of the MTW Supplement, but in practice, this is not a change from what a PHA can do without an MTW Waiver. Non-MTW PHAs can increase the payment standard to 110 percent of FMR under regular HCV program regulations. Exhibit 2-6. Approved Activities to Adjust the Reexamination Process

Reexamination Process Activities # of PHAs Approved to Use MTW Activity ( n = 21)

Alternative Reexamination Schedule for Households 18

Self-Certification of Assets 14

MTW = Moving to Work. PHA = public housing agency. Notes: Of the 31 Flexibility Cohort PHAs, 26 had an MTW Supplement approved as of March 31, 2023. Of these 26 PHAs, 13 operate both public housing and HCV programs, 10 operate only a Housing Choice Voucher (HCV) program, and 3 operate only a public housing program. HUD divides reexamination policy waivers by public housing and HCV residents. The exhibit aggregates them so that any PHA approved to implement one or more of the activities under the reexamination’s waiver category is represented only once per category. Activities for which no PHA has approval are not listed. Sources: MTW Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements

The activities under the reexamination’s waiver fall into two categories:

• Alternative Reexamination Schedule for Households. The alternative reexamination schedule allows PHAs to change the frequency of reexaminations. Under regular program rules, reexaminations often happen annually; with the waiver, PHAs can opt to conduct reexaminations biennially or triennially. Increasing cost efficiency related to staff time and streamlining operations was the primary motivation for PHAs in selecting this activity. Improving self-sufficiency among residents was the other motivation. PHAs said that reducing the frequency of reexaminations would free up PHA staff time to do other activities. They also said less frequent reexaminations were beneficial for residents who experience an income increase because that income would not be reported to the PHA until the next reexamination. As such, residents will not see an increase in their share of rent until their next reexamination, which could be 1 or more years away from when the increase in income occurred. PHAs expect that residents will be encouraged by this policy to find and keep employment. This change also allows residents to save more of their income, which is expected to improve residents’ self-sufficiency.

PHAs varied in whether the alternative reexamination schedule policy depended on household composition or annual income. For example, at one PHA, households with fixed incomes (often elderly or disabled households) were moved to a triennial reexamination schedule because their income is not expected to change much year over year. Working households were moved to a biennial schedule. Some PHAs chose to keep households with an annual income below a certain limit on an annual reexamination schedule. PHAs said they believed this would encourage those households to find employment so they could move to a biennial reexamination schedule, which is less burdensome for the residents and PHA staff. The most common challenge with this change was adjusting the PHAs’ software to track the new reexamination schedule and flag when households would be due for their next reexamination. 24

Across all PHAs, this activity includes a hardship policy, which typically allows households to request an interim reexamination if they have a decrease in income or a change in household composition. Exhibit 2-7 details how each PHA implements the alternative reexamination schedule.

24 See exhibit 2-15 for a discussion on how software reporting issues have affected implementing this waiver. • Self-Certification of Assets. Household assets are considered when establishing how much rent a public housing or HCV resident is responsible for paying. This waiver allows residents to self-certify up to $50,000 in assets, meaning residents do not need to obtain or submit substantiating documentation of their assets. PHAs selected this activity primarily to reduce the burden on PHA staff and residents and promote cost efficiency. Requiring documentation of assets can cause delays in approving new residents or making payments to landlords because PHAs need to wait for banks to complete and return certification forms. The certification process also caused hardships for residents because some banks charge a nonreimbursable fee to verify statements or complete certification forms. Some PHAs said they also saw this activity as promoting self-sufficiency by encouraging residents to build their assets without imposing additional paperwork requirements. PHAs typically applied this new policy to all assisted households and did not report any significant challenges in implementing the change. Exhibit 2-7. Implementing Alternative Reexamination Schedules

Public housing agencies (PHAs) implementing biennial or triennial reexamination schedules have taken various approaches to rolling out this change. Among the approaches taken to stagger which households start on the updated reexamination schedule are— • Alphabetical by last name: Households are divided into two or three groups (depending on whether the switch is to

biennial or triennial) based on last name. For example, if moving to biennial, households with last names falling between A and M switch to biennial after their reexamination in the year of implementation. Households with last names falling between N and Z switch to biennial after their reexamination the following year.

• By public housing building: One PHA is assigning biennial reexamination schedules by public housing building. For

example, all households in one or two developments switch to biennial reexaminations after their current reexamination, then households in the remaining buildings switch to biennial the next cycle.

• By month of reexamination: One PHA is rolling out biennial reexaminations based on which month the household is scheduled for a reexamination. Households scheduled to have their reexamination in odd months (for example, January, March, May) switch to a biennial schedule after the current reexamination. Next year, households with a reexamination

scheduled during even months (for example, February, April, June) switch to biennial.

Most PHAs highlighted the importance of staggering the reexamination schedule so that staff workloads are balanced. These approaches are intended to allow case managers to split reexaminations near evenly across 2 or 3 years.

Sources: MTW Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements 2.3.4 Landlord Leasing Incentives

Ten PHAs are approved to implement landlord leasing incentives to encourage landlord participation in the HCV program. Exhibit 2-8 lists the number of PHAs approved to implement each specific landlord leasing incentive. The primary goal of implementing landlord leasing incentive activities is to expand housing choice for HCV residents. Although landlord incentives represent increased expenditures for PHAs, PHAs said they believed the opportunity to expand landlord participation in the HCV program was worth the expense. Many PHAs also chose to implement landlord incentives with other activities that decrease PHA expenditures or increase PHA revenue to help offset the increased cost.

Getting landlords involved has been a challenge, so we’re throwing as much money as possible at them to get them involved. … The ability to access additional funds above what we can pay for Fair Market Rent is probably the biggest driver [for increased

landlord participation]. With 14-17 percent inflation on property maintenance increases after COVID[-19], it’s been hard to keep up [and be competitive] with Fair Market Rents.

—PHA interviewee

Exhibit 2-8. Approved Activities to Implement Landlord Leasing Incentives

Landlord Leasing Incentive Activities # of PHAs Approved to Use MTW Activity ( n = 10)

Other Landlord Incentives (HCV—Tenant-Based Assistance) 10

Damage Claims (HCV—Tenant-Based Assistance) 5

Vacancy Loss (HCV—Tenant-Based Assistance) 4

HCV = housing choice voucher. MTW = Moving to Work. PHA = public housing agency. Notes: Of the 31 Flexibility Cohort PHAs, 26 had an MTW Supplement approved as of March 31, 2023. Of these 26 PHAs, 13 operate both public housing and HCV programs, 10 operate only an HCV program, and 3 operate only a public housing program. Landlord leasing incentive waivers are exclusively for the HCV program. Activities for which no PHA has approval are not listed. Sources: Moving to Work (MTW) Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements The specific landlord incentives include—

• PHA-Defined “Other” Landlord Incentives. This activity allows PHAs to define and implement landlord incentives that do not fall under the damage claims or vacancy loss activities. These incentives are usually financial bonuses to increase landlord participation in the program. Exhibit 2-9 details how PHAs define this activity.

• Damage Claims. This activity allows PHAs to compensate landlords participating in the HCV program for any damages beyond normal wear and tear—or what would be covered by a security deposit—if a resident leaves the unit damaged. The damage claim cannot exceed the lesser of the cost of repairs or 2 months of contract rent. PHAs said they saw this activity as a way to increase or maintain housing options for HCV residents by incentivizing landlords to participate in the HCV program by reducing their risk of monetary loss. To further encourage continued landlord participation in the program, some PHAs have stipulated that the damage claim payment will be paid only when a new HAP contract is executed, meaning a new HCV recipient occupies the vacated unit.

• Vacancy Loss. Vacancy loss incentives allow PHAs to pay a landlord as much as 1 month of contract rent to keep a unit available while another housing choice voucher (HCV) recipient is identified and completes the paperwork required to occupy the unit. The goal of this activity is to increase the retention of current program landlords in the HCV program. A larger pool of landlords participating in the HCV program is also expected to help HCV recipients lease up more quickly.

Exhibit 2-9. How Public Housing Agencies Use Other Landlord Leasing Incentives Waivers

Ten public housing agencies (PHAs) are approved to implement PHA-defined “other” landlord incentives within their Housing Choice Voucher (HCV) programs. The Moving to Work (MTW) Operations Notice stipulates that these incentives

should be designed to encourage new landlords to join the HCV program. The incentives cannot be greater than 1 month of contract rent and can be paid only on execution of a new Housing Assistance Payment (HAP) contract. Among the 10 PHAs with approval to implement this activity, the “other” landlord incentives are defined as— • New Unit Payments. Five PHAs offer landlords an incentive of as much as 1 month’s rent for each unit not previously

rented through the HCV program leased to an HCV recipient. The definition of a new unit varies by PHA. Some PHAs consider a new unit as one that an HCV recipient has not leased for at least 12 months. Other PHAs define a new unit as a unit that an HCV recipient had never leased. At least one PHA varies the incentive amount depending on whether the unit is completely new to the HCV program or is returning after not being leased by an HCV recipient for at least 1 year. The PHA may cap total payments to a single landlord under this program to one payment a year or a maximum

monetary amount. The COVID-19 waivers to HCV program rules that have since expired previously authorized this activity. At least one PHA selected to implement this activity under MTW because of the success it saw when implemented under the COVID-19 waiver. The goal of this incentive is to increase housing choice and HCV use by increasing landlord participation in the HCV program.

• New Landlord Incentives. Four PHAs offer incentives to new landlords to participate in the HCV program. The PHAs all defined a new landlord as one that has never participated in the HCV program before. It is typically a one-time incentive payment that varies by PHA from $250 to $500 to a full month of contract rent. The goal of this incentive is to increase housing choice and HCV use by attracting more landlords to the program. • Referral Incentives. Two PHAs offer landlord referral bonuses of $250 to $500. Both PHAs provide the bonus to

landlords who refer another landlord to the PHA resulting in the execution of a new HAP contract for an HCV recipient with the referred landlord. The PHAs differ in their eligibility criteria, however. One PHA restricts the incentive to referred landlords that have no prior experience renting to HCV recipients, and the other restricts it to landlords who have not leased to an HCV recipient in the past 5 years. Like other incentives, the goal under this waiver is to expand landlord participation in the HCV program, increase housing choice for residents, and move more families from the HCV waiting list.

• Other Incentives. Three PHAs implement additional incentives under this waiver. One PHA offers a $25 property maintenance bonus and an initial $50 Housing Quality Standards (HQS) bonus to landlords if the unit being rented passes the HQS inspection on the first visit. Another PHA offers security deposit assistance of up to 1 months’ rent

under this activity. The third PHA offers a one-time $250 signing bonus for each new HAP contract executed, with the goal of increasing owner participation in the HCV program.

PHAs notify landlords of these new incentives through newspaper advertisements, landlord events, word of mouth, flyers, working with realtors, and social media. However, the initial success of these activities varied by PHA. One PHA had been implementing the incentive for new landlords for more than a year and had seen only two or three new landlords join the

HCV program. The PHA attributed the lack of success to landlords being able to make more profit from renting to market-rate renters and the perceived stigma of renting to HCV recipients. Another PHA had been implementing the new unit payments for more than 2 years (including when the incentive was authorized under the COVID-19 waiver) and reported issuing one to two new unit incentive checks a month.

Sources: MTW Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements 2.3.5 Housing Quality Standards

Twelve PHAs are approved to implement Housing Quality Standards (HQS) process changes. These policies apply only to the HCV program and do not change the HQS inspection standards defined in the program regulations. Exhibit 2-10 lists which HQS adjustments these PHAs are approved to implement and how many PHAs are approved to implement each specific activity. Exhibit 2-10. Approved Activities to Adjust Housing Quality Standards Processes

Housing Quality Standards (HQS) Activities # of PHAs Approved to Use MTW Activity ( n = 12)

Alternative Inspection Schedule 6

Third-Party Requirement 5

Prequalifying Unit Inspections 3

MTW = Moving to Work. PHA = public housing agency. Notes: Of the 31 Flexibility Cohort PHAs, 26 had an MTW Supplement approved as of March 31, 2023. Of these 26 PHAs, 13 operate both public housing and Housing Choice Voucher (HCV) programs, 10 operate only an HCV program, and 3 operate only a public housing program. HQS waivers are exclusively for the HCV program. Activities for which no PHA has approval are not listed. Sources: MTW Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements

The three activities being undertaken via the HQS waivers include—

• Alternative Inspection Schedule. This activity allows PHAs to set a local inspection schedule for all or a portion of its HCV units. Under the waiver, inspections must occur at least once every 3 years, and residents must be allowed to request an interim inspection. Although all PHAs said they adopted this change to promote staff efficiencies to free up staff time for other activities, implementation of this activity varies by PHA. Three of the six PHAs are imposing restrictions on which units qualify for less frequent HQS inspections. For example, one PHA uses the policy to move HQS inspections from annual to biennial but only for units that have passed at least the past two consecutive inspections. Another PHA is shifting from biennial to triennial HQS inspections but also limits the policy to units that passed the HQS during the first inspection (that is, no major issues were found, and no reinspection was needed). The only challenge reported in implementing this waiver was delays in updating the PHA’s software to track units on the alternative inspection schedule.

• Third-Party Requirement. Under this activity, the PHA is allowed to conduct HQS inspections on PBV units that it owns, manages, or controls. PHAs say they selected this change to streamline operations and increase efficiency.

[As] a smaller jurisdiction … securing a qualified, reliable third-party inspection can prove to be costly or time-consuming to execute. Without a reliable third-party inspection, families face delays in occupancy.

—PHA interviewee

The cost and delays associated with partnering with a third-party agency should be eliminated by shifting the responsibility to PHA staff.

• Prequalifying Unit Inspections. This activity allows PHAs to prequalify or preinspect units as many as 90 days before an HCV recipient occupies the unit to ensure the unit meets HQS. HCV participants must also be allowed to request an interim inspection. The preinspection length varies from 30 to 90 days across the three PHAs approved for this waiver. One PHA said that the waiver will be particularly helpful when inspecting new projects or complexes that become available because all units could be inspected at once.

We didn’t see a negative to expanding the period of time between unit turnover and lease-up. If a unit passed inspection and is sitting empty, what new issues are going to come up?

—PHA interviewee

PHAs anticipate that the policy change will streamline the lease-up process, expand the use of HCV, and reduce inspection costs by reducing costs for reinspection related to the timeliness of the inspection.

2.3.6 Short-Term Assistance

One PHA is approved to implement a short-term assistance program. The MTW Operations Notice specifies that such a program should be designed for specific populations, such as those who are hard to house or those who are at risk of or experiencing homelessness. The PHA approved for this waiver provides 12 months of emergency assistance to households experiencing homelessness that are certified by a local support agency. The PHA expects to serve 10 households through this program each fiscal year. The PHA said the goal behind this program was two-fold. The PHA has an elderly preference for its HCV program’s waiting list. Because of this, the PHA found that other populations needing housing assistance were not making it off the waiting list. This short-term assistance program helps the PHA serve other vulnerable populations. Secondly, the PHA anticipates this program to help promote self-sufficiency among the households served. Households served through this program are offered the opportunity to transition to the HCV program if they meet certain criteria. After entering the short-term assistance program, nonelderly, nondisabled households must obtain employment within 6 months (per the PHA’s work requirement) and enter the PHA’s Family Self-Sufficiency (FSS) program. After 12 months of stability, households are eligible to transition to the HCV program (subject to availability). 2.3.7 Term-Limited Assistance

One PHA is approved to impose term-limited assistance for public housing residents. The PHA implements this activity with other activities in what the PHA calls its Steppingstone program for nonelderly, nondisabled households. All households are limited to 5 years of public housing assistance. Households can apply for a maximum of two 1-year extensions, capping their total time in public housing to 7 years (regardless of consecutiveness). At that point, the household cannot reapply for the PHA’s public housing program. Households receive supportive services as they prepare to graduate from the public housing program. The PHA’s goal for this activity is to encourage residents to become self-sufficient. The first cohort of residents is expected to reach the 5-year term limit in November 2026. 2.3.8 Project-Based Voucher Program Flexibilities

Seven PHAs are approved to implement changes to their PBV program.25 PBV units are rental units available only to HCV recipients. Households issued PBVs do not need to search for rental units on the open market (as households issued a tenant-based voucher would need to) because PBV units are available. Exhibit 2-11 lists which PBV program changes these PHAs are approved to implement and how many PHAs are approved to implement each specific activity.

25 As de Sousa et al. (2023) reported, as of April 2022, of the 30 interviewed Treatment PHAs, 11 already use PBVs as part of their HCV program or through a Rental Assistance Demonstration (RAD) conversion of their public housing stock. Another PHA had a PBV project under development. Exhibit 2-11. Approved Activities to Implement Project-Based Voucher Program Flexibilities # of PHAs Approved to Use Project-Based Voucher (PBV) Program Activities MTW Activity ( n = 7)

Increase PBV Project Cap 5

Elimination of PBV Selection Process for PHA-Owned Projects 5 Without Improvement, Development, or Replacement

Increase PBV Program Cap 4

Limit Portability for PBV Units 4

Alternative PBV Selection Process 1

Alternative PBV Unit Types (Shared Housing and Manufactured 1 Housing)

Increase PBV HAP Contract Length 1

Increase PBV Rent to Owner 1

HAP = Housing Assistance Payment. MTW = Moving to Work. PHA = public housing agency. Notes: Of the 31 Flexibility Cohort PHAs, 26 had an MTW Supplement approved as of March 31, 2023. Of these 26 PHAs, 13 operate both public housing and HCV programs, 10 operate only an HCV program, and 3 operate only a public housing program. PBV program flexibility waivers are exclusively for the HCV program. Sources: MTW Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements The activities approved under the PBV program flexibility waivers include—

• Increasing PBV Project Cap and Increasing PBV Program Cap. Under these two activities, PHAs can (1) increase the share of PBV units within a housing development to as much as 100 percent and (2) increase the cap on the share of project-based units to as much as 50 percent of either the PHA’s total authorized units or its annual budget authority. Although these two activities are distinct, the motivation for PHAs to select them was similar. Several of the PHAs approved to implement one or both of these activities selected the activities to support future development goals, such as new affordable housing developments tied to tax credits, upcoming Rental Assistance Demonstration (RAD) conversions to allow the PHA to convert public housing developments into PBV units, or upcoming renovation and preservation projects, with the goals of offering more housing choices to program participants and to preserve existing affordable housing.

[PBVs] serve as an option to help finance new affordable housing projects and to financially stabilize struggling affordable housing projects.

—PHA interviewee

• Eliminating the PBV Selection Process for PHA-Owned Projects Without Improvement, Development, or Replacement. Under regular program regulations, PHAs must select PBV proposals through a competitive process (or based on a prior competition). This activity allows PHAs to eliminate that selection process when the PHA awards PBVs to nonpublic housing properties it owns. Under the activity, PHAs are also not required to engage in an initiative to improve, develop, or replace a public housing property or site when awarding PBVs to PHA-owned properties. PHAs were motivated to select this activity to

support future development goals, such as new affordable housing developments tied to tax credits, upcoming RAD conversions, or upcoming renovation and preservation projects. One PHA selected this activity because it has historically received very limited responses to the PBV selection process and hoped eliminating the selection process would allow it to develop a strong relationship with a single, reliable developer. The goal of the activity is to expand housing choice for program participants and preserve existing affordable housing.

• Limiting Portability for PBV Units. This activity allows PHAs to waive the requirement to provide a tenant-based voucher if requested by a PBV household after residing in a PBV unit for 12 months. All four PHAs approved to implement this activity have increased to 24 months, the threshold to qualify for obtaining a tenant-based voucher. PHAs said they selected this activity to help address issues related to the shortage of affordable housing within their jurisdictions, which means that PBV households trying to move with a tenant-based voucher are not likely to be successful. This activity has the potential to decrease the administrative burden on PHA staff. Some PHAs report that it might also increase housing stability and strengthen residents’ ties to a community.

• Establishing Alternative PBV Selection Process. Under this activity, a PHA may establish an alternative competitive process for awarding PBVs owned by nonprofits, for-profit housing entities, or the PHA (excluding public housing). The PHA that selected this activity said it did so to increase the opportunity to acquire PBV units in the future to expand housing choice for residents.

• Incorporating Alternative PBV Unit Types (Shared Housing and Manufactured Housing). This waiver allows PHAs to attach and pay PBV assistance to shared housing or manufactured housing units. The PHA using this policy incorporates existing shared housing situations into the PBV program to increase housing options for veterans experiencing homelessness.

• Increasing PBV HAP Contract Length. The PHA approved for this policy change uses it to extend the length of the PBV HAP contract to as many as 50 years, including extensions. The PHA said the goal of this activity is to ensure the longer term viability of PBVs and improve housing choice for residents.

• Increasing PBV Rent to Owner. Under this activity, PHAs can develop a local process to determine PBV rent to owner. The PHA said it selected this change to promote a sustainable, affordable housing market while “ improving housing standards by allowing owners better cashflow to improve their existing property .” 2.3.9 Family Self-Sufficiency Program with Moving to Work Flexibility

Seven PHAs are approved to implement changes to their FSS program. The FSS program promotes increased earnings and savings among families in public housing or HCV programs by working with residents to set and achieve education and employment goals. FSS participants are provided case management, supportive services, and a financial incentive in the form of savings paid to an escrow account to offset rent increases that result from higher earnings. On successful completion of the program, participants receive full access to escrow funds, which can be used for any purpose. Exhibit 2-12 lists which adjustments these PHAs are approved to implement and how many are approved to implement each specific activity. Exhibit 2-12. Approved Activities to Adjust the Family Self-Sufficiency Program

Family Self-Sufficiency Program Activities # of PHAs Approved to Use MTW Activity ( n = 7)

Waive Operating a Required FSS Program 4

Modify or Eliminate the Contract of Participation 2

Policies for Addressing Increases in Family Income 2

MTW = Moving to Work. PHA = public housing agency. Notes: Of the 31 Flexibility Cohort PHAs, 26 had an MTW Supplement approved as of March 31, 2023. Of these 26 PHAs, 13 operate both public housing and HCV programs, 10 operate only an HCV program, and 3 operate only a public housing program. FSS program with MTW flexibility waivers can be applied to the public housing or HCV program. Activities for which no PHA has approval are not listed. Sources: MTW Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements

The three approved activities include—

• Waiving Operating a Required FSS Program. This waiver allows PHAs statutorily required to operate an FSS program to waive the requirement. Three of the four PHAs approved for this activity said they requested it because their FSS programs were already inactive and wanted to remove the requirement. The fourth PHA had only one mandated participant in its FSS program and wanted to remove the requirement to operate the program because the current participant was not engaging with the program or meeting set goals. None of these four PHAs sought approval to replace their FSS program with an MTW self-sufficiency program.

• Modifying or Eliminating the Contract of Participation. Under this activity, PHAs may modify the terms of or eliminate the FSS Contract of Participation and replace it with a local form. 26 Both PHAs said they use the waiver to make the program more favorable for FSS participants. One PHA now considers the graduation from the program requirement as being met if any adult in the household is employed, not only the head of household, and removing the requirement to be off Temporary Assistance for Needy Families (cash assistance). The other PHA has shifted from an escrow model to a goal rewards model that provides cash incentives for meeting certain goals related to income, finance, education, health, employment, and other areas. Participants may opt to receive the incentive immediately or have it deposited into a PHA-managed savings account on their behalf. By switching from the escrow to the goal rewards model, the PHA said it anticipates more program participants will be encouraged to complete their goals.

FSS is one of the best programs HUD has developed, but if someone was already working when they came into the program, there were few incentives to participate.

—PHA interviewee

• Setting Policies for Addressing Increases in Family Income. Under this activity, PHAs are allowed to set new policies for whether increases in FSS participants’ income are recognized for purposes of increasing rent or changing the amount of funds moved to escrow through the FSS program. One of the PHAs approved for this change also has shifted to a triennial reexamination schedule. Under this policy, the PHA allows households in the FSS program

26 The Contract of Participation is a HUD form that describes the FSS participant’s (the head of household) rights and responsibilities when engaging with the program and the administering PHA’s rights and responsibilities.

to request an annual reexamination if their income increases by 10 percent or more. The goal is to allow these households to have income increases recognized so households can change the amount of funds placed in the escrow through the FSS program. The other PHA approved for this waiver has shifted from an escrow model to a goal rewards model, under which increases in income are not considered and do not contribute to an increase in escrow.

2.3.10 Moving to Work Self-Sufficiency Program

Six PHAs are approved to implement an MTW Self-Sufficiency program. The MTW Operations Notice defines MTW Self-Sufficiency programs as any “existing self-sufficiency and training programs, and any successor programs.” PHAs can use the activities under this waiver category to be exempt from certain HUD program requirements. Exhibit 2-13 lists which MTW Self-Sufficiency program components these PHAs are approved to implement and how many PHAs are approved to implement each specific activity. Exhibit 2-13. Approved Activities to Implement a Moving to Work Self-Sufficiency Program

Moving to Work (MTW) Self-Sufficiency Program Activities # of PHAs Approved to Use MTW Activity ( n = 5)

Alternative Family Selection Procedures 4

Policies for Addressing Increases in Family Income 2

PHA = public housing agency.

Notes: Of the 31 Flexibility Cohort PHAs, 26 had an MTW Supplement approved as of March 31, 2023. Of these 26 PHAs, 13 operate both public housing and Housing Choice Voucher (HCV) programs, 10 operate only an HCV program, and 3 operate only a public housing program. MTW Self-Sufficiency program waivers can be applied to the public housing or HCV program. Activities for which no PHA has approval are not listed. Sources: MTW Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements The two approved activities include—

• Alternative Family Selection Procedures. This activity allows PHAs to develop their own recruitment and selection process for their MTW Self-Sufficiency programs, requiring participation from all nonelderly and nondisabled households. All four PHAs said they use this activity to make participation in their self-sufficiency programs mandatory. Three PHAs apply the policy to all nonelderly, nondisabled adults; one PHA restricts the mandate to nonworking, nonelderly, nondisabled household members. They said these program changes aim to promote self-sufficiency and provide residents with the tools needed to graduate from public housing or HCV program successfully. This activity includes a hardship policy across all four PHAs.

• Policies for Addressing Increases in Family Income. Under this activity, PHAs set policies for handling income increases related to rent increases or changes in the amount of funds moved to an escrow or savings account during participation in the MTW Self-Sufficiency program. One PHA uses this waiver to allow residents entering the MTW Self-Sufficiency program to be exempt from the minimum rent requirements for up to 1 year. The program also mirrors FSS program escrow policies to encourage employment. The other PHA has disregarded income increases for the purpose of increasing rent until the next scheduled reexamination. At that point, income increases phase-in over the next 2-year period (between reexaminations); however, to qualify for the Earned Income Disregard, any increase in income must be reported within 30 days. The goal of this program is also to support self-sufficiency and encourage households to obtain and maintain employment. 2.3.11 Work Requirements

Four PHAs are approved to implement a work requirement.27 This waiver allows PHAs to require public housing or HCV residents who are at least 18 years old and neither elderly nor disabled to work or engage in an acceptable substitute for work, as defined by the PHA, such as education, job training, work readiness programs, volunteer work, or life-skills courses. Some PHAs further restricted eligibility for the work requirement to exempt live-in aides, individuals who are the primary caretakers for a child younger than 6, and pregnant women. Under the policy, the maximum requirement allowed is 15 hours of work or another productive activity per week if applied to all eligible household members or 30 hours per week if applied to the entire household. All four PHAs opted to implement the work requirement at the maximum allowed. The waiver also requires that residents of a household subject to the work requirement be given 6 months to meet it before terminating participation in the public housing or HCV programs for noncompliance.

The goals for selecting this waiver among the PHAs were similar and intended to encourage residents to work, become financially independent, and graduate from the housing assistance program. As one PHA noted: “ This activity will move participant families toward self-sufficiency and financial independence .” To help residents succeed, some PHAs couple the work requirement with supportive services, such as onsite job training and job placement services offered by local partners or community colleges.

Three of the four PHAs began implementing the work requirement, but not without challenges. Two PHAs said that some residents had voluntarily left the public housing or HCV program once the work requirement went into effect, or they requested to port their voucher to another PHA that does not have MTW or a work requirement. This activity requires a hardship policy so that people who cannot work for an approved reason can be exempted. All three PHAs have received hardship requests (two to seven per PHA). The PHAs said the hardship requests were often filed after residents applied for disability and were conditionally approved, pending the final disability status determination. 2.3.12 Public Housing as an Incentive for Economic Progress

One PHA is approved to implement this waiver. Under this waiver, the PHA allows households to remain in public housing while being “over income”—earning more income than is allowed to qualify for public housing assistance—for up to 3 years. 28 However, residents are notified that they are over-income at least 1 year before the end of the grace period to remain in public housing. At the end of the 1-year notification period, the household may opt to remain in public housing for an additional year, but the monthly rent will be adjusted to be the greater of the applicable FMR or the amount of the monthly subsidy the PHA pays for the unit through public

27 Among the four PHAs approved to implement a work requirement, two PHAs operate only HCV programs, one operates only a public housing program, and one operates both a public housing and an HCV program. The PHA

operating both applies the work requirement to residents in both programs. 28 Under PIH Notice 2019-11(HA) (available here https://www.hud.gov/sites/dfiles/PIH/documents/PIH-2019-11.pdf ), all PHAs are permitted to allow households to remain in public housing while their income exceeds 120 percent of the area median income (AMI) for 2 consecutive years. Per the Notice, “a PHA must terminate the

family’s tenancy within 6 months of the second income determination or charge the family a monthly rent equal to the greater of (1) the applicable FMR; or (2) the amount of monthly subsidy for the unit, including amounts from the operating and capital fund, as determined by regulations.” housing Operating and Capital Funds. The PHA has not yet had to apply this policy to residents but anticipates that doing so supports the eventual self-sufficiency of residents as they adjust to paying the full cost of rent. 2.3.13 Acquisition Without Prior HUD Approval

Two PHAs are approved to acquire housing sites without prior HUD approval to expedite the process of obtaining property to redevelop existing public housing. Among other requirements, under this activity, PHAs must submit materials for full HUD review within 30 days of acquisition. 29 Neither PHA had implemented this activity but sought approval because it saw it as “ an excellent tool to have when we look at future development .” One of these PHAs seeks to develop a nonprofit affiliate, allowing the PHA to act like a private housing developer, providing it more flexibility when acquiring property on the private market and seeking additional outside funding to support development. 2.3.14 Local, Nontraditional Activities

Seven PHAs are approved to implement local, nontraditional (LNT) activities. The MTW Operations Notice authorizes PHAs to use the LNT waivers to “provide a rental subsidy to a third-party entity to provide housing and supportive services to eligible low-income participants and to contribute MTW Funding to the development of affordable housing.” 30 Exhibit 2-14 lists which LNTs these PHAs are approved to implement and how many PHAs are approved for each specific LNT activity. Exhibit 2-14. Approved Activities to Implement Local, Nontraditional Activities

Local, Nontraditional Activities # of PHAs Approved to Use MTW Activity ( n = 7)

Housing Development Programs 5

Service Provision 3

Rental Subsidy Programs 0

MTW = Moving to Work. PHA = public housing agency.

Notes: Of the 31 Flexibility Cohort PHAs, 26 had an MTW Supplement approved as of March 31, 2023. Of these 26 PHAs, 13 operate both public housing and Housing Choice Voucher (HCV) programs, 10 operate only an HCV program, and 3 operate only a public housing program. Local, nontraditional waivers can be used by public housing and HCV programs. Sources: MTW Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements

• Housing Development Programs. This activity allows PHAs to use MTW funding flexibility to acquire, renovate, or build affordable housing units (excluding public housing) for low-income families. Per the MTW Operations Notice, this funding may take the form of gap financing for the development of affordable housing, PBV units, or tax-credit partnerships. A PHA cannot use more than 10 percent of its HAP budget to support this activity, and the families served must be at or below 80 percent of the area median income. All PHAs that applied for this waiver said they did so to increase the supply of affordable housing in their jurisdictions, often in response to a shortage of affordable units for

29 Under this waiver, MTW PHAs must also comply with and have documentation that the project is in compliance with local zoning, commission an independent appraisal of the site, and conduct an environmental assessment. See

24 CFR 905.608(e) and 24 CFR 905.608(f) for more details. 30 The MTW Operations Notice can be found at https://www.hud.gov/sites/dfiles/PIH/documents/FinalMTWExOpsNoticePartVIWeb.pdf.

households with very low incomes or specific populations. One PHA plans to use this waiver to improve a building it already owns, adding PBVs to the site for larger households needing affordable three- or four-bedroom units, which are in short supply in the region. A second PHA plans to use the LNT waiver to acquire an old hotel converted to efficiency suites that the PHA believes it could manage and maintain better. Another PHA plans to use the LNT waiver to support the development of supportive housing for youth aging out of foster care.

Utilizing up to 10 percent of HAP dollars for housing development will provide much-needed acquisition funds as well as “match” or “leverage” dollars to competitive funding applications. Utilizing funds in this way will generate more units of housing for low and very low-income households. This activity contributes to a strategic goal of [Randolph County Housing Authority], which is to expand the affordable housing stock in its jurisdiction.

—MTW Supplement for Randolph County Housing Authority

• Service Provision. Under the LNT waiver, PHAs can use MTW funding flexibility to provide HUD-approved self-sufficiency or supportive services not otherwise permitted under public housing and HCV regulations. PHAs may also extend these services to low-income individuals not in the PHA’s public housing or HCV programs. The three PHAs approved for this LNT took varying approaches—

o Brighton Housing Authority has allocated as much as $145,000 in HAP funding to support activities that may include a housing navigation service, a career and college launch program, support to a domestic violence emergency shelter, food assistance (meals delivery) to PHA residents who are elderly, a technology library program, case management services to voucher households, COVID-19 vaccine clinics, and a youth tutoring program. The PHA plans to serve approximately 1,400 people through these LNT services to support resident needs, education goals, and eventual homeownership.

o The Housing Authority of Newnan is approved to provide support services to as many as eight occupants at a time at a transitional housing facility for low-income residents not in the public housing or HCV program. The PHA plans to partner with local service agencies to provide housing and other supportive services for the households residing in these units.

o The Housing Authority of Cheraw has implemented self-sufficiency and support services for its public housing and HCV residents. The first is a one-time (per fiscal year) $500 incentive payment to as many as 35 households that maintained 1 year of full-time employment, with no more than a 2-week gap in employment. A lottery selects households if more than 35 qualify. The PHA also provides financial assistance for residents with children or youth to subsidize their participation in after-school activities, such as cheerleading, dance, or football. The PHA requests documentation of the fee for the activity and either pays the program fees directly or reimburses residents after receiving their payment receipt. The PHA has implemented the activities for more than a year and said the response from residents has been very positive.

• Rental Subsidy Programs. This LNT waiver allows PHAs to use MTW funding flexibility to provide a rental subsidy to third-party entities (excluding landlords or tenants) that manage

the implementation of the subsidy program. No PHAs are currently approved for this activity.

2.3.15 Agency-Specific Waiver

One PHA—the Washington County Community Development Agency—is approved to implement an activity through an agency-specific waiver. Under this waiver, the PHA allows landlords to self-certify that a unit rented through the HCV program has no life-threatening deficiencies on the move-in date. The PHA completes a physical unit inspection within 60 days of move-in. As stated in the approved MTW Supplement, the agency’s goals for this waiver are to allow it to:

[1] complete calculations and issue contracts with the landlords [in a] timely [manner], [2] potentially cut administration expenses of the program, and [3] allow tenants to move into units more rapidly and [prevent tenants from] incurring additional rent burden (Washington County, 2022).

The policy also allows the PHA to incorporate move-in inspections in the annual inspection schedule, saving PHA staff travel time. 2.4 Use of Funding Flexibility to Support Moving to Work Activities

Funding flexibility is one of the first actions PHAs could take after receiving MTW designation because its use is not contingent on having an approved MTW Supplement. Of the 31 Flexibility Cohort PHAs, 11 reported using funding flexibility for a range of activities. Three PHAs described using funding flexibility to help pay for new MTW administrative costs, such as partial salary for an MTW coordinator, consultant fees, or software upgrades. Seven PHAs said they use their public housing Operating Fund, public housing Capital Fund, HAP allocations, and HCV administrative fees (including HCV reserves) to support MTW activities directly. These funds support landlord incentives, housing navigation, tenant security deposits, employment services and other resident enrichment programs, and further subsidization of tenant rents exceeding payment standards. Four PHAs use funding flexibility to support development or redevelopment activities in their housing portfolio.

Of the 31 Flexibility Cohort PHAs, 16 reported that they plan to use funding flexibility in the future to support resident services, administrative efforts, landlord incentives, or development activities. Most of these PHAs are waiting to implement funding flexibility until they have more experience with MTW administration, have realized savings from other MTW efforts, implemented more MTW activities, observed the maturation of current MTW activities, or completed new development projects. Among the PHAs that said they were waiting to realize cost savings before using funding flexibility, some said they rely on increased voucher use or increases in tenant rent to drive the anticipated cost savings. PHAs have continued to be cautious about implementing funding flexibility until they understand the process and its potential challenges more clearly.

Three Flexibility Cohort PHAs reported that they did not plan to use funding flexibility, primarily because their current funding sources were adequate. 31 Two of these PHAs administered only a public housing or HCV program. 2.5 Public Housing Agencies Without an Approved Moving to Work Supplement

Five Flexibility Cohort PHAs have not yet received final approval for their first MTW Supplement. Three of these PHAs are drafting their MTW Supplement and have not yet submitted it to HUD. HUD is reviewing one PHA’s MTW Supplement. One PHA’s MTW Supplement was returned for additional public feedback.

PHAs reported that these delays were related primarily to staff turnover among key positions at the agency. One PHA also had undergone software upgrades, making establishing concrete implementation plans for MTW activities more difficult. Others said they were working to narrow down or further specify their proposed activities after discussions with their field office or HUD MTW Office.

Several delayed PHAs said they hope to implement more than five different MTW activities, spanning cost-effectiveness, housing choice, and self-sufficiency in their first year of MTW. Proposed activities to promote cost-effectiveness include self-certification of assets, alternative recertification schedules, elimination of utility reimbursements, and HQS inspection schedule streamlining. Activities to support greater housing choice include landlord incentives, a greater initial rent burden, and increased payment standards. Activities to promote self-sufficiency include establishing a minimum rent, implementing a tiered rent structure, supplementing an FSS program, and instituting a work requirement. The overarching goals behind the PHA’s selection of these programs did not vary much from the reasons PHAs with approved MTW Supplements gave (as section 2.3 discusses). 2.6 Lessons Learned and Recommendations

Many PHAs described lessons learned in planning and implementing MTW activities. PHAs said that they learned to “take it slow” or “not take on too much” with the level of staff capacity available at a small PHA. They explained that this lesson involved educating staff across the organization about new MTW practices and procedures, ensuring that they align with new MTW goals. It also involves reserving enough time to think fully through the possible repercussions of each activity on residents, staff, agency processes, and reporting needs. Updating procedures, communicating changes to residents, training staff, and aligning data systems takes additional time that must be built into implementation. PHAs said that implementing too much too quickly could mean missing important details or alienating staff and residents.

Some PHAs with limited staff capacity emphasized the importance of outside help. Several PHAs said that it was necessary to hire a consultant to help them address the complexity of MTW planning. PHAs also mentioned that good communication with the HUD field office and MTW Office provided important feedback on their plans that helped them better prepare to implement MTW activities. Connections with other MTW PHAs and the MTW Collaborative

31 The funding flexibility status for one PHA is unknown because it did not complete an interview with the evaluation team.

also provided essential guidance, example policies, and implementation strategies.32 To help address these challenges, one PHA recommended that HUD adjust the MTW Supplement process to occur biennially instead of annually, especially if the PHA is not seeking approval for additional activities.

In addition to staffing limitations, software system alignment was an ongoing frustration. Several PHAs said they would have planned activities differently if they had known that collecting and transmitting information through the new Housing Information Portal (HIP) would be difficult (exhibit 2-15). Implementing activities not yet aligned with HIP created an additional staff burden. Beyond HIP, other PHAs said the case management software they used to record resident services data did not interface well with other PHA systems. These challenges in implementation affirmed the need to “not take on too much” and expect unforeseen challenges that add time to implementation.

Most PHAs agree that MTW designation would be beneficial after activities are implemented and given time to take effect. They reported that the MTW process had encouraged creativity and innovation, allowing them to align resources at their agency better and gain more control over activities.

32 The MTW Collaborative is a nonprofit organization founded in 2019 that brings together and advocates for current and future MTW agencies. Exhibit 2-15. Challenges in Transitioning to the New Housing Information Portal

At the same time HUD is expanding Moving to Work (MTW), it is releasing a new data collection system named the Housing

Information Portal (HIP). HIP will replace the Inventory Management System/PIH Information Center (IMS/PIC) that public housing agencies (PHAs) currently use to report information on households, units, and tenant payment calculations. These and other data are collected via Form HUD-50058. The expectation was that HIP would be released before Flexibility Cohort PHAs began implementing any approved MTW

Waivers or associated activities. However, releasing HIP has been delayed indefinitely. The delay caused confusion among PHAs about whether to begin implementing some MTW Waivers and activities, and if so, how to report data for affected households to HUD. In late December 2022, HUD issued guidance to the Flexibility Cohort PHAs that provided several options for moving forward with implementing activities that cannot be reported in IMS/PIC until the release of HIP— • For households MTW activities do not affect: No changes to processes is required. PHAs can continue submitting data

to IMS/PIC using Form HUD-50058.

• For households an MTW activity affects that does not conflict with fields on Form-50058: PHAs may implement the MTW activity and continue submitting data to IMS/PIC using Form HUD-50058.

• For households an MTW activity affects that conflicts with fields on Form-50058: PHAs may implement the MTW activity if they can track the activity in their internal software system. PHAs were advised not to submit those actions to

HUD in IMS/PIC using Form HUD-50058 until HIP is released with an updated Form HUD-50058 for PHAs in the MTW expansion demonstration program.

MTW activities currently approved among Flexibility Cohort PHAs that PHAs said they could not report in IMS/PIC are—

• Most activities under the Tenant Rent Policies category, including utility reimbursements, minimum rent, elimination of deductions, alternative income inclusions or exclusions, initial rent burden, tenant payment as a modified percentage of income, standard deductions, and stepped rent.

• Alternative reexamination schedules.

Of the 26 PHAs with approved MTW Supplements, at least 12 delayed implementing at least one approved MTW activity because they cannot report new rent schemes or reexamination schedules in the current version of IMS/PIC.

It’s disappointing. I helped build [our updated software program over] all these nights and weekends … so it’s disappointing to have [our ability to report on clients] not work because HUD is not ready.

—PHA interviewee

Among the PHAs that have moved forward with implementing MTW activities that cannot be reported in IMS/PIC, they reported the delay in HIP has caused them to have to create manual workarounds or new systems to track client data. The magnitude of the issue varies by PHA, depending on which activities are implemented and how many households are

affected. PHAs reported that the changes range from affecting fewer than a dozen households to affecting all households served. Although PHAs have been working with their own software vendors to account for many of these changes, the vendors are limited in what they can release to PHAs until HIP and updated Form HUD-50058 for MTW Expansion PHAs are deployed. That limitation caused additional administrative work for these PHAs, partially offsetting the administrative efficiencies they were working toward with many of their MTW activities.

Source: Interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements

3. Approved Moving to Work Activities by Targeted Moving to Work Objectives

This chapter examines how individual Flexibility Cohort public housing agencies (PHAs) combine Moving to Work (MTW) Waivers and associated activities to meet one or more of the three MTW statutory objectives. By looking at the approved waivers and activities through the lens of the MTW objectives, this chapter provides a holistic and tangible picture of how the Flexibility Cohort PHAs use MTW flexibility.

The chapter starts with an overview of the number of approved MTW Waivers for each of the 26 Flexibility Cohort PHAs with approved MTW Supplements.

The next three sections consider the combinations of MTW Waivers and associated activities approved for each of the 26 PHAs, classified by the MTW statutory objective targeted: cost-effectiveness, self-sufficiency, or housing choice . The classification was based on which MTW objectives the PHAs listed in their MTW Supplements for the particular activity. Different PHAs sometimes had different MTW objectives for the same activity. For example, four PHAs have an approved waiver for a work requirement; two PHAs listed their objective as cost-effectiveness and self-sufficiency, and two PHAs listed only self-sufficiency as a goal. In those situations, discretion was used to classify under which MTW objectives to put that waiver. 33 The start of each section lists which approved waivers were associated with that objective. Appendix B provides PHA profiles that list every MTW activity that each of the 26 PHAs was approved to implement and which MTW objectives they reported targeting with that activity.

The final section of this chapter discusses the implementation timeline of MTW activities by PHAs with approved waivers. 3.1 Number of Approved Waivers by Public Housing Agency

As the Year 1 Annual Report describes (de Sousa et al., 2023), many PHAs highlighted the importance of starting slow but not all did so. Nearly half of the Flexibility Cohort PHAs with approved MTW Supplements (12 of 26) had six or fewer approved waivers, and three PHAs had three or fewer approved waivers. 34 On the other hand, 7 of the 26 PHAs had 11 or more approved waivers in their first year, including 3 PHAs with 20 or more approved waivers (exhibit 3-1). 35

33 In that example, work requirement waivers were classified under self-sufficiency, with a discussion about how such a waiver might affect costs included in section 3.2. Sheffield Housing Authority, the Housing and Redevelopment Authority of Hibbing, and McLeod County 34

Housing and Redevelopment Authority. 35 Housing Alliance and Community Partnerships, Bristol Redevelopment and Housing Authority, and Harrisonburg Redevelopment and Housing Authority. Exhibit 3-1. Number of Moving to Work Waivers Among the 26 Public Housing Agencies With Approved Moving to Work Supplements

7

6

HAs 5 f P 4 r o be 3 m

Nu 2

1

0

1 3 4 5 6 8 9 11 12 17 19 20 21 24

Number of Approved MTW Waivers

MTW = Moving to Work. PHA = public housing agency.

Source: MTW Supplements from the 26 Flexibility Cohort PHAs with approved MTW Supplements

The number of MTW Waivers approved by each PHA does not show how individual PHAs use their MTW flexibility. The following sections provide that picture by showing the combination of activities that individual PHAs selected—some of which include tweaks to standard program rules and more fundamental changes to others. 3.2 Approved Public Housing Agency Activities to Promote Cost-Effectiveness

Waivers for cost-effectiveness can reduce costs by reducing PHA staff time needed for an activity, reducing the amount of money needed for Housing Assistance Payments (HAP), and eliminating third-party payments. Any savings can be used to increase the provision of standard PHA activities, fund other MTW activities, or assist more households.

Activities chosen by Flexibility Cohort PHAs that reduce staff time needed for an activity include—

• Reducing the frequency of reexaminations.36 Reducing the frequency of Housing Quality Standards (HQS) inspections. • Changing standard deductions for the adjusted income calculation. • Eliminating deductions that are labor-intensive to verify. • Increasing the value of assets that can be self-certified. • Ignoring assets in calculating rent. • Increasing the time a voucher household must remain in a Project-Based Voucher (PBV) unit • before being eligible for a tenant-based voucher. Waiving operating a required Family Self-Sufficiency (FSS) program. • Streamlining a utility allowance schedule. • Eliminating a utility reimbursement. • 37

36 Some MTW activities, such as less frequent reexaminations (self-sufficiency incentive) and less frequent inspections (landlord incentive), are also counted as targeting one of the other statutory objectives.

37 Eliminating utility reimbursements reduces HAP payments, but in the interviews, PHAs reported that the major benefit of eliminating utility reimbursements is saving staff time in cutting and mailing the checks, canceling lost checks, and tracking down uncashed checks. • Eliminating an Earned Income Disregard.

This section focuses on the administrative efficiency part of cost-effectiveness, but other types of activities can also increase cost-effectiveness. Some additional PHA self-sufficiency activities (discussed in section 3.3) can reduce the amount of HAP subsidy needed. For example, increasing the minimum rent increases the tenant-paid portion of the rent for some households, thus reducing the HAP subsidy. Other self-sufficiency activities, such as a work requirement, can increase the work effort of assisted households, thus increasing their income and reducing the PHA’s HAP payment; however, administrative costs to track whether households meet the work requirement may increase. Cost-effectiveness depends on whether the amount that the HAP subsidy decreases is greater or less than the cost of tracking work requirement compliance.

PHAs can also reduce costs by obtaining waivers to eliminate third-party rent reasonableness verification and HQS inspection of properties that the PHA owns, manages, or controls. With these waivers, PHAs conduct the rent reasonableness verification and HQS inspection instead of hiring a third party. Four PHAs eliminated both third-party requirements, and one PHA eliminated the HQS third-party inspection requirement.

The rest of this section focuses on cost-effectiveness activities that increase administrative efficiency on an ongoing basis (rather than a one-time savings) by reducing staff time needed for an activity. 38

Of the 26 PHAs with approved MTW Supplements, 24 have an approved activity related to administrative efficiency. The most common activity to improve administrative efficiency— reducing the frequency of reexaminations (18 PHAs)—is a substantial change to the program and considerably reduces the amount of staff time spent on reexaminations and the administrative burden on assisted households, allowing households to grow their income for 2 to 3 years before their rent increases. The other two most common administrative efficiency activities are more modest, increasing the value of assets that can be self-certified (14 PHAs) and eliminating utility reimbursements (11 PHAs).

Of those 24 PHAs, 12 have approval for a combination of three or more administrative efficiency activities. Of the 12 PHAs, 10 have an MTW activity that reduces the number of reexaminations or HQS inspections and other administrative efficiency activities. The other two PHAs focused on simplifying the income calculation for determining rent.

Three PHAs tie for the most administrative efficiency activities with six activities: (1) New Smyrna Beach Housing Authority, (2) Bristol Redevelopment and Housing Authority, and (3) Harrisonburg Redevelopment and Housing Authority. At least half of the activities for all three PHAs relate to simplifying rent determinations, and all three eliminated utility reimbursements. New Smyrna Beach and Bristol also changed to triennial inspections. Bristol and Harrisonburg

38 Changing the selection process for PBVs is an example of an approved waiver expected to result in one-time or infrequent staff time savings. Five PHAs have such a waiver to eliminate the requirement that PHA properties selected for PBVs must have an initiative to improve, develop, or replace a public housing site and two PHAs have approval to choose an alternative to a competitive process for choosing PBVs. Another waiver example allows for

the acquisition of public housing sites without prior HUD approval, which increases efficiency in acquiring the property but is likely to be infrequent; then the PHA must provide all required documents to HUD within 30 days of the acquisition. Two PHAs have this waiver approved. also increased the time a PBV household must stay in their unit (from 1 year to 2 years) before being eligible for a tenant-based voucher (exhibit 3-2).

Exhibit 3-2. Administrative Efficiency Activities to Promote Cost-Effectiveness for Public Housing Agencies (PHAs) With Three or More Approved Activities ( n = 12) PHA Administrative Efficiency Activities Pomona Housing Authority • Streamlined utility allowance schedule. (CA) • Eliminated utility reimbursements. (HCV-only PHA) • Biennial reexaminations.

• Standard deductions for adjusted income calculation.

• Self-certification of assets up to $50,000.

Brighton Housing Authority • Streamlined utility allowance schedule. (CO) • Eliminated utility reimbursements. (HCV-only PHA) • Triennial reexaminations for elderly and disabled households.

• Self-certification of assets up to $25,000.

• Households must remain in project-based voucher (PBV) units for 2 years before tenant-based voucher eligibility.

New Smyrna Beach Housing • Streamlined utility allowance schedule. Authority (FL) • Eliminated utility reimbursements.

• Eliminated income deductions for nonelderly, nondisabled households for dependents, unreimbursed childcare costs, and disability assistance. • Eliminated Earned Income Disregard.

• Self-certification of assets up to $25,000.

• Triennial Housing Quality Standards (HQS) inspections.

Housing Alliance and • Streamlined utility allowance schedule. Community Partnerships (ID) • Eliminated utility reimbursements.

• Eliminated income deductions for dependents and unreimbursed childcare costs. • Triennial reexaminations for elderly and disabled households. • Biennial HQS inspections for units with good inspection histories.

Ruston Housing Authority • Triennial reexaminations for elderly and disabled households, (LA) biennial for other households. (PH-only PHA) • Eliminated income deductions or dependents and unreimbursed childcare costs.

• Self-certification of assets up to $25,000.

Rockville Housing Enterprises • Eliminated Earned Income Disregard. (MD) • Triennial reexaminations, except for households that have zero

income or pay minimum rent.

• Self-certification of assets up to $25,000.

• Households must remain in PBV units for 2 years before tenant-based voucher eligibility.

South Sioux City Housing • Streamlined utility allowance schedule. Agency (NE) • Eliminated utility reimbursements.

• Biennial reexaminations for elderly and disabled households. Housing Authority of Travis PHA Administrative Efficiency Activities • Streamlined utility allowance schedule. County (TX) • Eliminated income deductions for dependents and unreimbursed (HCV-only PHA) childcare costs.

• Biennial reexaminations.

• Self-certification of assets up to $25,000.

• Triennial HQS inspections.

Rosenberg Housing Authority • Eliminated utility reimbursements. (TX) • Eliminated all allowances and deductions from income. (HCV-only PHA) • Triennial reexaminations for elderly and disabled households, biennial reexaminations for working households, and annual reexaminations for households with no earnings.

• Asset income not used in calculating rent.

• Eliminated a required Family Self-Sufficiency program.

Bristol Redevelopment and • Eliminated utility reimbursements. Housing Authority (VA) • Eliminated income deductions for unreimbursed childcare expenses and medical expenses.

• Standard medical deduction for elderly and disabled families and standard childcare deduction for each child for working families. • Triennial reexaminations except for households with zero income. • Self-certification of assets up to $25,000.

• Households must remain in PBV units for 2 years before tenant-

based voucher eligibility.

Harrisonburg Redevelopment • Streamlined utility allowance schedule. and Housing Authority (VA) • Eliminated utility reimbursements of less than $20. (HCV-only PHA) • Eliminated deduction for unreimbursed childcare expenses.

• Eliminated Earned Income Disregard.

• Self-certification of assets up to $25,000.

• Households must remain in PBV units for 2 years before tenant-based voucher eligibility.

Randolph County Housing • Streamlined utility allowance schedule. Authority (WV) • Standard deduction of $2,000 for medical expenses for elderly and HCV-only PHA disabled households.

• Self-certification of assets up to $50,000.

HCV = Housing Choice Voucher. PH = public housing.

Sources: Moving to Work (MTW) Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements 3.3 Approved Public Housing Agency Activities to Promote Self-Sufficiency

MTW Waivers for activities encouraging self-sufficiency can either be implicit or explicit incentives. Implicit self-sufficiency activities eliminate or reduce the association of income and total tenant payment so that changes in earnings have no effect on total tenant payment (TTP) or change it less than the standard 30-percent adjusted income calculation. Explicit waivers either require or directly incentivize work or require self-sufficiency training.

Implicit self-sufficiency activities chosen by the Flexibility Cohort PHAs include39—

• Raising the minimum rent, which eliminates the relationship between income and rent for a larger range of incomes than the standard maximum minimum rent of $50. 40, 41 A stepped rent structure that changes the TTP independent of income. • Less frequent reexaminations that allow income gains for multiple years without changing • TTP. Exclusions of some earnings from income are used in the rent calculation so that some • increases in earnings do not affect TTP. Exclusion of asset income from the rent calculation so that increasing asset income does not • affect TTP. A time limit for assistance, which implies the household must be able to afford market rent • on their own after that time.

Explicit self-sufficiency activities chosen by Flexibility Cohort PHAs include—

• Work requirements. Mandatory participation in an MTW Self-Sufficiency program. • Incentive payments for meeting work or other self-sufficiency milestones. •

Of the 26 Flexibility Cohort PHAs with approved MTW Supplements, 20 have an approved waiver for an activity encouraging self-sufficiency.

Of the 20 PHAs, 8 are approved only for one self-sufficiency activity. However, 6 of those 8 PHAs have a substantial activity that impacts their entire nondisabled, nonelderly population.

• Four PHAs’ only self-sufficiency activity is conducting less frequent annual reexaminations for nondisabled, nonelderly households. 42 One PHA’s only self-sufficiency activity is mandating MTW Self-Sufficiency program • participation. One PHA’s only self-sufficiency activity is instituting a work requirement. •

All 12 PHAs with multiple self-sufficiency activities have one or more activities that substantially impact most of the PHA’s nonelderly, nondisabled households (for example, less frequent reexaminations or work requirements). Exhibit 3-3 shows the self-sufficiency activities

39 Elimination of utility reimbursements can also be thought of as implicit incentive to encourage earnings, because

a household that gets a utility reimbursement could earn a little more without increasing its TTP; however, the activity is not included here because the range of incomes this affects and the amount that earnings can increase is very small. Raising the minimum rent is counted only as one activity, even if the PHA received separate waivers to increase 40

the minimum rent for public housing and for HCV households. Unless otherwise stated, the activity includes all households the PHA serves (HCV, public housing, or both). This caveat also is true for other activities that have the same activity available for HCV and for public housing households but require two waivers. For one PHA, the approved activity stated the minimum rent increased from $50 to 30 percent of monthly income 41

(based on their annual reported income) for nonelderly, nondisabled households with an annual adjusted income of $2,000 or higher. This waiver was approved as part of the MTW Supplement, but in practice, is not a change in policy. A household with $2,000 or less in annual adjusted income would pay the minimum rent of $50 and a household with more than $2,000 would pay 30 percent of their income (as their TTP is above $50). It is not counted

as an activity to encourage self-sufficiency. 42 Less frequent reexaminations are only counted as a self-sufficiency activity if applied to nondisabled, nonelderly households. of the 12 PHAs approved to implement multiple self-sufficiency activities. The Ruston Housing Authority and the Harrison Redevelopment and Housing Authority have the most activities, with six each.

Exhibit 3-3. Self-Sufficiency Activities for Public Housing Agencies (PHAs) With Multiple Self-Sufficiency Activities ( n = 12) PHA Self-Sufficiency Activities

Ozark Housing Community • Work requirement of 15 hours per week. • Minimum rent increased to $130 in public housing. (AL)

New Smyrna Beach • Minimum rent increased to $130. • Triennial reexaminations. Housing Authority (FL)

Housing Authority of • Minimum rent increased to $130, except for households identified Newnan (GA) as full-time students.

• Biennial reexaminations.

Housing Alliance and • Minimum rent increased to $127. Community Partnerships • Percentage of income in total tenant payment (TTP) reduced to 27 (ID) percent.

• Excluded earnings for rent calculations for youth aged 18 to 21 and

full-time students aged 18 to 24 who are not heads, co-heads, or spouses of heads of household.

• Financial incentives for meeting goals in Moving to Work (MTW) Self-Sufficiency program or help paying education, training, or employment costs.

Ruston Housing Authority • Stepped rent. (LA) • Minimum rent increased to $130. (PH-only PHA) • Biennial reexaminations.

• Assistance limited to 5 years (with 2 years of extension possible). • Mandatory participation in MTW Self-Sufficiency program. • Work requirement of 15 hours per week or 780 hours per year.

Rockville Housing • Stepped rent with TTP to be stepped up by a minimum of 5 percent Enterprises (MD) each year for families on annual reexaminations and 10 percent every 3 years for families on triennial reexaminations.

• Minimum rent increased to $130.

• Income used for educational costs excluded for full-time students.

• Triennial reexaminations, except for households with zero income or that pay minimum rent.

Ripley County Public • Mandatory participation in MTW Self-Sufficiency program. Housing Agency (MO) • Work requirement of 15 hours per week. (HCV-only PHA)

Robeson County Housing • Stepped rent of 4 percent of Fair Market Rent each year. Authority (NC) • Triennial reexaminations.

• Mandatory participation in MTW Self-Sufficiency program for any household member not working.

Dover Housing Authority • Income from assets not counted for rent calculation. (NH) • Biennial reexaminations.

Housing Authority of Travis • Minimum rent increased to $75. County (TX)

PHA Self-Sufficiency Activities

(HCV-only PHA) • TTP reduced to 28 percent of adjusted income.

• Biennial reexaminations.

Rosenberg Housing • Minimum rent increased to $100. Authority (TX) • Percentage of income in TTP reduced to 27.5 percent. (HCV-only PHA) • Income from assets not counted in rent calculation.

• Biennial reexaminations for working families and annual reexaminations for families with no earnings.

Harrisonburg • Minimum rent increased to $100. Redevelopment and • TTP increased to 35 percent of adjusted income. Housing Authority (VA) • School grants and funding excluded from income. (HCV-only PHA)

• Earnings from dependents aged 20 and younger excluded from income. • Triennial reexaminations.

• MTW Self-Sufficiency program pays cash incentives for meeting self-sufficiency goals.

HCV = Housing Choice Voucher. PH = public housing.

Notes: Unless stated otherwise or relevant only to the HCV program, activities apply to public housing and HCV households if the PHA serves both. Minimum rent, work requirements, term limits, and mandatory MTW Self-Sufficiency participation are for nonelderly, nondisabled households. Sources: MTW Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements

The Ruston Housing Authority, a public housing-only PHA, has made the most fundamental changes for assisted households of any Flexibility Cohort PHA, with a work requirement, a stepped rent, and a 5-year term limit for assistance. Ruston PHA is only one of four Flexibility Cohort PHAs approved to implement a work requirement, one of three PHAs with a stepped rent, and the only PHA with a term limit. 43

The Harrisonburg PHA, a housing choice voucher (HCV)-only PHA, has six self-sufficiency activities. Although the activity changes are more modest than the Ruston PHA, they appear to be chosen to work together. The most substantial change is switching to triennial reexaminations, allowing households 3 years to grow their income without an increase in rent and saving significant PHA staff time. Harrisonburg PHA also increased the minimum rent to $100 and increased the minimum TTP to 35 percent of adjusted income. These changes reduce HAP costs and may offset some of the foregone decreases in HAP for households that do not have to report income increases until their next triennial reexamination. This PHA made some income exclusions for students and workers younger than 20 that could affect a targeted group of households and changed from an FSS program with escrow accounts to an MTW Self-Sufficiency program with cash rewards for meeting self-sufficiency goals.

43 The South Sioux City Housing Agency (NE) has a work requirement, but it is not shown in exhibit 3-4 because it has approval for only one self-sufficiency activity. 3.4 Approved Public Housing Agency Activities to Promote Housing Choice

Flexibility Cohort PHAs sought to increase housing choice for assisted households by providing incentives to increase landlord willingness to participate in the HCV program or directly expanding the number of units available to voucher holders.

Landlord incentive activities chosen by Flexibility Cohort PHAs to increase landlord willingness to rent to voucher holders include—

• Offering financial incentives, such as bonus payments to new landlords. Offering to pay damage claims or security deposits. • Offering to pay for vacancy loss between renting to two voucher holders. • Allowing prequalifying HQS inspections. • Having less frequent HQS inspections. •

Activities chosen by Flexibility Cohort PHAs to expand the number of units available to voucher holders include—

• Increasing the payment standard.44 Increasing the allowable initial rent burden. • Adding PBV units. •

Of the 26 Flexibility Cohort PHAs with an approved MTW Supplement, 19 have an approved waiver for an activity encouraging housing choice. Of those 19 PHAs, 5 have approval for both landlord incentive and expanding the number of units available to voucher holder activities; 9 PHAs have approval for only a landlord incentive activity; and 9 PHAs have approval for only an activity to increase the available of units to voucher holders.

Exhibit 3-4 shows the 14 PHAs with an approved landlord incentive activity. Of the 14 PHAs, 10 offer a substantial bonus for new landlords or landlords renting new units that have not previously been rented to an HCV recipient. The bonuses range from $250 to $1,000 (with two PHAs offering bonuses of up to 1 month of rent, which could be more than $1,000). Although standard PHAs can offer landlord bonuses, they can only pay these incentives using administrative fees and other non-HAP funding. MTW PHAs have funding flexibility and can use HAP and public housing funding for landlord bonuses. 45 The next most common landlord incentives involve substantial changes to the standard program: less frequent inspections (six PHAs) and paying up to 1 or 2 months of rent for damage claims (five PHAs) or up to 1 month of rent for vacancy loss (four PHAs).

44 Increases in payment standards could lead to more landlord participation, but this activity is in the expanded number of units category because theoretically the landlord with units only available at the higher payment standard was willing to rent to voucher holders but could not because the voucher holder could not pay the rent.

45 Standard PHAs can offer landlord incentives but have less flexibility than MTW PHAs on which funds can be used for this purpose. Standard PHAs were previously allowed to use administrative fee reserves and other non-HAP funding for landlord incentives. The June 2022 Notice (PIH2022-18) now allows PHAs to use regular administrative fees for landlord incentives and HUD communication indicates PHAs were encouraged to use administrative fees

for landlord incentives in 2020. Source, HUD communications on May 26, 2022, and Administrative Fee Eligible Uses Notice (https://www.hud.gov/sites/dfiles/PIH/documents/PIH2022-18.pdf). With MTW funding flexibility, MTW PHAs can also use HAP and public housing funding for landlord incentives. Exhibit 3-4. Landlord Incentive Activities for Public Housing Agencies (PHAs) to Promote Housing Choice ( n = 14) PHA Landlord Incentive Activities Sheffield Housing Authority • Bonus of as much as $500 for new units leased to housing choice (AL) voucher (HCV) households.

Pomona Housing Authority • Damage claim of as much as 1 month’s rent. (CA) a • Bonus of $250 for new Housing Assistance Payment contracts in the city of Pomona.

Solano County Housing • Vacancy loss of as much as 1 month’s rent. Authority (CA) • Damage claim of as much as 2 months’ rent.

• Bonus of 1 month’s rent if an HCV household has not occupied the unit in the previous 12 months. • Allowed prequalifying inspections valid for 90 days.

New Smyrna Beach Housing • Triennial inspections. Authority (CA)

Housing Authority of Newnan • Damage claim of as much as $1,000. (GA) a • Bonus of as much as $1,000 for renting units not previously occupied

by voucher households.

Housing Alliance and • Vacancy loss of as much as 1 month’s rent. Community Partnerships (ID) a • Damage claim of as much as 1 month’s rent.

• Bonus of $300 for renting new units to households off the waiting list. • Biennial inspection for units with good inspection history.

Washington County • Agency-specific waiver that allows landlords to self-certify that units Community Development do not have any life-threatening emergencies for move-ins (Housing Agency (MN) Quality Standards inspection must be scheduled within 60 days of moving in).

Housing Authority of Cheraw • Bonus of $500 for up to 10 new landlords in the HCV program. (SC) a Maryville Housing Authority • Bonus of as much as $500 for new landlords. (TN) Housing Authority of Travis • Bonus of as much as 1 month’s rent for landlord that has never County (TX) a participated in the HCV program.

• Less frequent inspections but no less frequent than every 3 years.

Rosenberg Housing Authority • Triennial inspections if unit passes initial inspection and first biennial (TX) a inspection on first visit (PHA will switch to biennial inspections and then move to triennial inspections for qualifying units).

Bristol Redevelopment and • Vacancy loss of as much as 1 month’s rent. Housing Authority (VA) a • Bonus of $500 for first-time lease up.

• Bonus of $200 for retention.

• Bonus of $500 for referring landlords who have not participated in the program during the past 5 years.

• Bonus of $25 for property maintenance and $50 for passing inspection on the first visit.

• Triennial inspection if unit passes biennial inspection on the first visit (PHA is already on a biennial inspection schedule).

Harrisonburg Redevelopment • Vacancy loss payment of as much as 1 month’s rent. and Housing Authority (VA) a • Damage claims of as much as 1 month’s rent.

PHA Landlord Incentive Activities

• Bonus of $250 for landlords who have never rented to an HCV

household.

• Bonus of $250 for referring a new landlord.

• Security deposit of as much as 1 month’s rent (limited to once per household). • Prequalifying inspection valid for up to 60 days.

Brattleboro Housing Authority • Triennial inspections. (VT)

a This PHA also has waivers for multiple self-sufficiency incentives. Notes: Less frequent reexaminations for fixed-income tenants are counted as administrative efficiency (cost-effectiveness objective) but not reported in this exhibit. One PHA not in this exhibit excluded 25 percent of earnings of tenants aged 18 to 30 who are not heads of household in calculating income for the rent determination. Sources: Moving to Work (MTW) Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements.

Bristol Redevelopment and Housing Authority and Harrisonburg Redevelopment and Housing Authority have the most landlord incentive activities, with six activities each. Bristol PHA’s landlord incentives focus on financial incentives, with four of the activities being different types of cash bonuses to landlords 46 and another being vacancy loss payments. Bristol PHA complemented these financial incentives to try to increase landlord participation by reducing the burden for landlords participating in the program for multiple years with triennial inspections if the unit passed the previous inspection on the first visit.

Harrisonburg PHA has a $250 cash bonus for new landlords or for the referral of a new landlord, but the rest of their activities make renting to a voucher holder less risky: Prequalifying inspections so that a landlord does not have to risk a unit being rejected from the program and losing their renter during the lease-up process; security deposit and damage claims to financially ensure against the risk of renters damaging the units; and vacancy loss payments that reduce the risk of a unit being vacant payment between two voucher household renters. 47

Raising the payment standard is the most common MTW activity for directly expanding the number of available units for voucher holders. Eight PHAs have approval to raise the payment standard to 120 percent of the Fair Market Rent (FMR). 48 Standard PHAs cannot raise the payment standard above 110 percent of FMR. 49 This activity makes additional units available to voucher holders—units renting between 110 and 120 percent of FMR—without the voucher

46 Some of these separate financial incentive activities are covered under the same waiver (Other Landlord Incentives for HCV: Waiver 4.c).

47 Harrisonburg tied for being the PHA with the most self-sufficiency activities. Including Harrisonburg, seven of the PHAs with landlord incentive activities also had multiple self-sufficiency activities (indicated by [ a ] in exhibit 3-4). One additional PHA with an approved waiver that increased payment standards to 110 percent of FMR was not 48

included in this count because standard PHAs can raise the payment standard to 110 percent. 49 Standard PHAs can establish a payment standard of up to 120 percent of FMR for a household with a person with a disability if necessary for reasonable accommodation. Standard PHAs can apply to HUD for an exception payment standard up to 120 percent of rent for some of their service area. All PHAs can also change to Small Area Fair

Market Rents (SAFMRs) and set the payment standard up to 110 percent of SAFMR, which may be higher than FMR in some areas and lower in others. For more detail on payment standards, see HowToSeekHigherPaymentStandards.pdf (nhlp.org) .

household’s rent burden exceeding 30 percent of their adjusted income.50 The PHA pays the difference between rent and 30 percent of income for units not exceeding the payment standard and meeting HQS and rent reasonableness requirements.

PHAs can also make more units available to new voucher holders by increasing the allowable initial rent burden to more than 40 percent. This increase makes more units available to voucher households, but the voucher holder pays the full difference between the payment standard and the rent, increasing the financial strain on these families. Families may be willing to make this trade-off. Five PHAs have approval to implement this activity, with allowable initial rent burdens increased to 45 percent at one PHA, 50 percent at three PHAs, and 60 percent at one PHA. None of the PHAs raised both the payment standard and the allowable initial rent burden.

Adding PBV units can also expand the number of units available to voucher holders by adding to the supply of units that meet the HCV program requirements. Increasing the cap on the share of units in a building that can be PBV units could make previously unavailable housing available to voucher holders. Increasing the cap on how many tenant-based vouchers the PHA can make project-based overall could make units available in a rental market with a scarcity of affordable housing or make units available for individual households having a hard time finding a landlord willing to rent to them or needing accessible units or housing linked to supportive services. On the other hand, converting tenant-based vouchers to PBVs may eliminate some potential benefits of the HCV program for deconcentrating assisted housing locations, depending on PBV development locations.

Four of the Flexibility Cohort PHAs obtained approval to increase their PBV project cap from 25 percent to 100 percent and their PBV program cap from 20 to 50 percent. One PHA received approval to increase only its PBV project cap. One additional PHA obtained approval to allow shared housing in a PBV unit, expanding the housing available for veterans exiting homelessness. 51 3.5 Timeline for Implementing Activities

The timeline for implementing MTW Waivers varies by PHA, but most PHAs with approved MTW Supplements started some of their MTW activities by the time of the interviews in early 2023. Many PHAs implemented their approved activities at separate times rather than all at once. Some PHAs said they were unsure when certain activities would go live because of software delays or other unique circumstances.

Exhibit 3-5 depicts the implementation timeline of the first activities for PHAs with approved waivers. Three PHAs reported implementing their first MTW activities in 2021, and four additional PHAs implemented their first activity in the first half of 2022. Seven PHAs had at least one MTW activity operating for at least 6 months in 2022, the year in which impacts from MTW activities are measured in this report. This timing is important because activities likely need to be in place for some time before effects can be observed. PHAs continued to implement

50 For PHAs that have alternative rent structures, their TTP may not be 30 percent of adjusted income but increasing the payment standard makes more units available at the standard rent policy for that PHA. Waivers to implement LNT activities can expand the number of units available to voucher holders. For example, 51

if an LNT activity supports development of affordable housing, presumably some of the units will be available to voucher holders but not necessarily in the short term. LNT activities are not included here. See exhibit 2-14 and the discussion that follows in section 2.3.14 for more information on LNT activities. MTW activities in late 2022 and early 2023. Ten additional PHAs implemented their first activity in the second half of 2022, and five additional PHAs started implementing activities in the first quarter of 2023. The other four PHAs with approved MTW Supplements plan to start implementation later in 2023. Exhibit 3-5. Implementation Timing of Approved Moving to Work Activities

30 26

25 22

20 17

15

10 7 10 3 5

0 3 5 4 4

Number of PHAs That Began Implementing Their MTW Activities This Quarter Number of PHAs With at Least One Active MTW Activity

MTW = Moving to Work. PHAs = public housing agencies. Q1 = first quarter. Q2 = second quarter. Q3 = third quarter. Q4 = fourth quarter. Sources: Moving to Work (MTW) Supplements; interviews conducted from February through March 2023 with PHA staff from the 26 Flexibility Cohort PHAs with approved MTW Supplements

Nearly all PHAs reported that the implementation of approved MTW activities had been delayed compared with their original timeline. Delays were due to longer than expected timeframes for MTW Supplement submission and approval, more effort needed than expected to lay the groundwork for implementing activities, and problems aligning software systems that support required reporting. Delays in the MTW Supplement submission and approval process were mainly due to a lack of staff capacity during the pandemic, a need to clarify and whittle down proposed activities, a desire by PHAs to align their MTW designation timing with their fiscal year, and technical issues with the submission portal. These delays are discussed in more detail in the Year 1 Report (de Sousa et al., 2023). PHAs also reported that more time was needed to fully understand the ripple of changes to be addressed in PHA processes when MTW activities went live. New processes need to be designed, manuals rewritten, staff retrained, communications sent to partners and residents, and new tracking systems need to be designed. These issues seemed to multiply as PHAs came closer to implementation and took greater staff capacity and lead time than anticipated. Section 2.6 discusses these issues in more detail. At the same time, many PHAs were transitioning to new software platforms that would help them interface as MTW agencies with the Housing Information Portal (HIP). This transition was responsible for many of the implementation delays. Exhibit 2-15 further details delays due to HIP and software transitions. 4. Changes Over Time, Control Group Activities, and Significant Legislation

This chapter describes how current Year 2 activities of the Flexibility Cohort public housing agencies (PHAs) differ from what was planned originally during their first year of implementation when they first applied for Moving to Work (MTW) designation. It then discusses how PHAs assigned to the control group are moving forward their own goals to improve cost-effectiveness, self-sufficiency, and housing choice within traditional program regulations or through non-MTW-related waivers issued by HUD. The chapter concludes with a discussion of recent policy changes that are expected to take effect in 2024 and how those changes may affect both Flexibility Cohort and control group PHAs. 4.1 Summary of Planned Activities Compared with Earlier Moving to Work Plans

Flexibility Cohort PHAs outlined their long-term vision for using MTW flexibility in their initial MTW plans, as reported in Part 2 of the MTW application and the baseline year interviews conducted by the evaluation team. The evaluation team collected updated information on what activities PHAs were approved to, or sought to, implement during Year 1 of their MTW designation by reviewing the PHAs’ approved MTW Supplements and conducting interviews with staff from 30 of the 31 Flexibility Cohort PHAs. 52 This section compares PHAs’ initial long-term plans for MTW with their approved or planned activities in Year 1 of MTW designation (2021–22) and Year 2 of MTW designation (2022–23). This discussion draws from the approved waivers and activities as reported in approved MTW Supplements for 26 of the 31 Flexibility Cohort PHAs and includes information on which waivers and associated activities 4 of the 31 Flexibility Cohort PHAs plan to include in their first MTW Supplements. 53

Exhibit 4-1 displays the number of waivers PHAs were approved to implement (for those with an approved MTW Supplement) or planned to seek approval for (for those without an approved MTW Supplement) in Year 1 (2021) and Year 2 (2022) compared with their 5-year plans for MTW reported in their MTW application before being designated an MTW agency (2020). PHAs continue to wait to implement the full suite of waivers they eventually hope to implement until later years, when they fully understand how initial changes work in practice, when software and reporting systems are fully operational to support the changes being made, or when disruptions caused by staff turnover have settled. In some cases, either because of leadership changes or reconsideration, they may no longer plan to seek all the waivers listed in their MTW application.

52 During the 2022 round of data collection, the Township of Neptune Housing Authority (NJ-048) was unavailable to complete an interview with the evaluation team and did not have an approved MTW Supplement as of April 2022. This PHA was not included in the descriptions of the planned use of waivers for Year 1. Year 1 interviews were conducted from February through April 2022 and covered PHA activities during 2021 and early 2022.

53 Fayetteville Housing Authority (AR181/AR097) declined to participate in an interview with the evaluation team and did not have an approved MTW Supplement as of April 2023. This PHA is not included in the analyses reported in this chapter. Exhibit 4-1. Flexibility Cohort Public Housing Agencies’ (PHA) Plans for Moving to Work (MTW) Waiver Use Over Time From Baseline to Year 2

1. Tenant Rent Policies 28 25 24

2. Payment Standards and Rent Reasonableness 15 14 15

3. Reexaminations 31 24 25

4. Landlord Leasing Incentives 21 11 13

5. Housing Quality Standards 15 15 13

6. Short-term Assistance 6 1 1

7. Term-limited Assistance 9 2 1

8. Increase in Elderly Age 2 0 0

9. PBV Program Flexibility 11 4 8

10. FSS Program with MTW Flexibility 18 6 8

11. MTW Self-Sufficiency Program 7 4 5

12. Work Requirements 18 5 5

13. PH as an Incentive for Economic Progress 2 0 1

14. Moving-on Policy 0 0 0

15. Acquisition without Prior HUD Approval 12 2

16. Deconcentration of Poverty in Public Housing 2 0 0

17. Local Nontraditional Activities 23 7 9

0 5 10 15 20 25 30 35

Baseline Year Year 1 Year 2

FSS = Family Self-Sufficiency. MTW = Moving to Work. PBV = project-based voucher. PH = public housing. Notes: See appendix I of the Operations Notice for more information on these waivers (HUD, 2020), numbered in the exhibit to align with their number in the Operations Notice. Of the 31 Flexibility Cohort PHAs, 1 PHA without an approved MTW Supplement did not complete the Year-1 interview with the evaluation team. Therefore, it is not included in Year-1 numbers, because the researchers did not know which waivers it planned to approve at that time. Another PHA did not complete the Year-2 interview with the evaluation team and is not included in the table for Year 2. Of the 31 Flexibility Cohort PHAs, 15 operate both public housing and Housing Choice Voucher (HCV) programs, 13 operate only an HCV program, and 3 operate only a public housing program. Some of the waivers represented in the table have multiple activities that fall under that waiver. The exhibit aggregates them so that any PHA planning to request one or more activities under a waiver category is represented only once per category. Sources: MTW Supplements; interviews conducted from February through March 2023 with PHA staff at 30 of the 31 Flexibility Cohort PHAs; interviews conducted from February through March 2022 with PHA staff at 30 of the 31 Flexibility Cohort PHAs; responses to Part 2 of the MTW application; baseline interviews in March 2021 with PHA staff from the 31 Flexibility Cohort PHAs

Among the PHAs that had prepared, or were working on, their second MTW Supplement, most sought reapproval for the same activities approved in their first MTW Supplement. Those PHAs that made changes did so to—

• Add New Activities. Some PHAs that decided to start small in the first year have added, or are planning to add, additional high-priority activities for the PHA or activities that help to meet additional statutory objectives. For example, one PHA focused its initial efforts on activities that would support cost-effectiveness to free up resources and staff time to support additional activities to promote self-sufficiency.

• Make Clarifications. Some PHAs changed the population to which already approved waivers would apply or clarified processes to address unintended consequences from activities included in their first MTW Supplement, such as using too broad of a definition for those who qualified for a waiver.

• Remove Activities. Some PHAs that started with many activities in their first MTW Supplement narrowed down the list of activities to improve management of the changes or respond to a leadership change.

Similar to Year 1 of MTW designation, PHAs often highlighted the importance of starting slowly to maintain a manageable amount of change, for both PHA staff and residents. Although these PHAs may still be interested in implementing more complex changes, such as LNTs or work requirements, they plan to wait until later years to pursue them.

4.2 Activities Undertaken by Non-Moving to Work Public Housing Agencies (Control Group)

Efforts implemented and associated study outcomes by Control PHAs with similar characteristics were tracked to ensure that the effect of MTW designation on PHA and resident outcomes can be distinguished from business as usual. In February 2023, an online survey with executive directors from the 10 Control PHAs and the 2 Treatment PHAs that did not move forward with MTW designation was conducted to detail any activities they were undertaking or planned to undertake in the next year related to the three MTW statutory objectives. If the PHA indicated they were undertaking activities in one or more of these areas, they were asked to complete an interview to learn more about these activities. Of the eight PHAs that completed the survey, all were from Control PHAs. Among these eight, five Control PHAs reported implementing new activities related to the MTW statutory goals and were selected for additional followup. Three of the five Control PHAs identified for followup answered the questions.

Among the five PHAs who reported implementing activities related to the MTW statutory goals, three PHAs reported implementing new activities related to cost-effectiveness, three PHAs reported implementing new activities related to housing choice, and two PHAs reported implementing new activities related to self-sufficiency. These activities may lead to slight improvements in study outcomes for these PHAs, such as reductions in PHA operating expenses, improvements in resident income, or increases in the share of residents living in low-poverty areas.

Two Control PHAs implemented activities that streamline operating procedures and may reduce operating expenses. One PHA continues to offer the option to conduct virtual reexamination

appointments started during the COVID-19 pandemic and allows residents to mail interim recertifications. Another PHA has switched to biennial Housing Quality Standards (HQS) inspections as allowed under the 2016 streamlining rule to free up staff time and reduce administrative burden. 54

Three Control PHAs implemented activities with the goal of making it easier for voucher holders to access affordable housing in low-poverty neighborhoods. One of these efforts required HUD to approve an exception payment standard. This exception allows the PHA to set the payment standard at up to 120 percent of the Fair Market Rent (FMR) for part of their service area. A similar MTW payment standard waiver is broader, allowing the 120 percent payment standard for their entire service area. The other efforts implemented at Control PHAs to increase housing choice do not require HUD waivers but may still allow voucher households to access units in low-poverty neighborhoods. One PHA project-based 15 vouchers at a new development in a low-poverty neighborhood. A second PHA helped pass a local housing bond with a set-aside for affordable housing. This PHA also offers landlord incentives, including security deposit assistance to open new units for housing choice voucher (HCV) holders, and hired a housing navigator to offer housing search services to residents. 55

One PHA implemented an activity that may increase resident household income but does not require a HUD waiver. The PHA encourages more residents to enroll in its Family Self-Sufficiency (FSS) program by updating the FSS contract to offer more time to complete FSS goals. 4.3 Effect of Housing Opportunity Through Modernization Act Changes

In February 2023, updated rulemaking under the Housing Opportunity Through Modernization Act (HOTMA) of 2016 was published in the Federal Register Notice to revise regulations around the HCV and public housing programs. 56 Under the revised regulations, similar flexibilities to some MTW Waivers currently available to MTW Expansion PHAs will be available to all PHAs. Starting January 1, 2024, all PHAs will be able to implement administrative changes to their HCV or public housing programs, including—

• Allowing residents to self-certify assets up to $50,000. Allowing for additional income and asset exclusions when determining resident income. • Increasing the threshold to deduct medical expenses from income calculations. • Eliminating the use of the Earned Income Disallowance. •

54 For more information on streamlining annual reexaminations, see https://www.hud.gov/sites/documents/16-05PIHN.PDF .

55 The PHA offering landlord incentives also received Emergency Housing Vouchers (EHV). They specified that these efforts applied to their HCV program. A second PHA also receiving EHVs reported offering landlord incentives to EHV recipients only. The EHV program was funded under the American Rescue Plan Act of 2021 to provide up to 70,000 housing choice vouchers to PHAs across the United States to help households experiencing or

at risk of homelessness; fleeing or attempting to flee domestic violence; or recently homeless to find permanent housing. PHAs receiving EHVs get funds that they can use for landlord incentives and housing navigation. As of April 18, 2022, three Control Group PHAs received EHVs, ranging in award size from 15 to 29 vouchers, and six Flexibility Cohort (Treatment Group) PHAs received EHVs ranging in award size from 15 to 78 vouchers.

56 For the full notice, see the February 14, 2023 issue of the Federal Register (88 FR 9600), docket number FR-6057-F-03, available here https://www.federalregister.gov/documents/2023/02/14/2023-01617/housing-opportunity-through-modernization-act-of-2016-implementation-of-sections-102-103-and-104 . • Reducing the frequency of interim income reexaminations and eliminating interim reexaminations solely for increases in earned income.

Although these changes are largely administrative, one of the goals for the changes was to encourage HCV and public housing residents to earn and save more money (by allowing more asset accumulation and fewer reexaminations). This goal aligns closely with the MTW statutory objective of promoting self-sufficiency. During the interviews with the Flexibility Cohort PHAs, three PHAs said that the new HOTMA rules would make some of their currently approved MTW activities moot. Some also said that they no longer plan to seek approval for certain waivers via the MTW Supplements because the desired changes, such as eliminating the use of the Earned Income Disregard, will be generally allowable for all PHAs once the updated regulations take effect.

It is possible that these changes, if, or when, adopted by the Control PHAs, could result in improved resident outcomes. Many of the previously mentioned changes can be applied by PHAs to encourage public housing and HCV residents to earn and save more. If that occurs, the impact of being an MTW PHA may be reduced.

5. Interim Impacts on Outcome Measures

As outlined in Research Design / Data Collection and Analysis Plan (Turnham et al., 2021), this is the first annual report to present the impact of the opportunity to apply for Moving to Work (MTW) designation on the three MTW statutory objectives of cost-effectiveness, household self-sufficiency, and housing choice , and other outcomes. With implementation by the Flexibility Cohort public housing agencies (PHAs) still in the early stages, this report focuses on a limited set of outcomes to minimize undue focus on differences between the Treatment and Control PHAs that might arise by chance. Differences that appear by chance rather than the effect of MTW flexibility are even more likely this year than in future years because implementation is in the early stages.

This impact study compares confirmatory outcomes Exhibit 5-1. Confirmatory and Exploratory in the 33 Treatment PHAs versus the 10 Control Outcomes PHAs. One confirmatory outcome is associated with each of the three MTW objectives. The three A confirmatory outcome is judged to be the best single confirmatory outcomes are presented and discussed measure of whether Treatment public housing agencies in this chapter. Appendix C presents results for the (PHAs) have achieved that statutory objective. A exploratory outcomes and discusses only statistically statistically significant finding from the confirmatory hypothesis test provides definitive evidence that Moving to significant impact estimates for exploratory Work (MTW) flexibility has a nonzero impact on that outcomes (exhibit 5-1). objective. During the research design phase of this evaluation Exploratory outcomes provide a more complete picture in 2020, HUD and the evaluation team recognized of the potential impact of MTW on the objective. These that the small size of the control group ( n = 10) may outcomes can be alternative measures of the confirmatory outcome, outcomes measured for portions of PHA not produce precise estimates, limiting the ability to programs or participants served, or components of a analyze the impact of MTW for certain types of multipart confirmatory outcome measure. A statistically PHAs (such as those with only voucher programs). significant finding from an exploratory hypothesis test To supplement the findings of the impact study’s provides suggestive, but not definitive, evidence that MTW experimental analysis, the evaluation team added a flexibility has a nonzero impact on that objective. quasi-experimental analysis, selecting a matched group of 99 Comparison PHAs that are similar in observable characteristics to the Treatment PHAs. This Year 2 Annual Report does not present results for the quasi-experimental analysis (Treatment versus Comparison PHAs). However, the (unpublished) differences between the Treatment PHAs and Comparison PHAs were used to judge the reliability of the impact estimates generated from the experimental analysis (Treatment versus Control PHAs).

Exhibit 5-2 illustrates the Treatment, Control, and Comparison groups and the comparisons made between group outcomes to assess the impacts of the opportunity to apply for MTW designation (the intervention).

Exhibit 5-2. Moving to Work Treatment, Control, and Comparison Groups and Related Impacts

PHA = public housing agency. QED = quasi-experimental design. RCT = randomized controlled trial (experimental analysis). 5.1 Confirmatory Outcomes

This section discusses the impact estimates for the confirmatory outcome for each of the three MTW statutory objectives. Section 5.2 discusses exploratory outcomes. 5.1.1 Cost-Effectiveness

The MTW statutory objective related to cost-effectiveness is “to reduce cost and achieve greater cost-effectiveness in federal expenditures.” 57 For this evaluation, the primary question related to this objective is whether MTW PHAs can provide a similar level of housing assistance at a lower cost than non-MTW PHAs, which is best evaluated by comparing PHA expenditures per household per month. Expenditures comprise a PHA’s annual costs for housing choice voucher (HCV) administrative activities, Housing Assistance Payments (HAP), and annual public housing operating expenses. To finalize the cost-effectiveness measure, total expenditures are divided by the total number of unit months leased for the PHA HCV and public housing programs. This measure is at the PHA level. The data for both total expenditures and the number of unit months leased are from the annual PHA income statement in the HUD Financial Data Schedule.

In Year 2, no statistically significant difference was observed between Treatment and Control PHA expenditures per household as measured by the PHAs’ annual financial reports submitted to HUD in 2022 (exhibit 5-3). This finding likely stems from the large variance in

57 Section 204 of the Omnibus Consolidated Rescissions and Appropriations Act of 1996 (1996 Act). average per-household monthly expenditures and the small sample size for analysis at the PHA level. Exhibit 5-3. Estimated Impacts of Offering Moving to Work Cohort 1 Designation, Year 2 (2022)

Confirmatory Outcome Treatment Control Impact p-value

Total operating, administrative, and HAP expenditures per household, per month a $730 $629 $101 0.140

Household earnings in a year $23,944 $21,466 $2,478 0.078*

HCV households living in low-poverty census tractsb 33.1 30.7 2.4 p.p. 0.052* HAP = Housing Assistance Payment. HCV = housing choice voucher. p.p. = percentage point. * Statically significant at the p < 0.10 level. a Impact analysis focuses on public housing agency (PHA)-level data, so the true sample size of PHAs with sufficient data for this measure is small (33 Treatment PHAs, of which 26 had sufficient data for this outcome measure; 10 Control PHAs, of which 9 had sufficient data).

b Means are estimated using only PHAs with voucher programs (29 Treatment PHAs, 8 Control PHAs). Notes: This sample includes 43 PHAs (33 Treatment PHAs, 10 Control PHAs). Expenditures per household are analyzed at the PHA level. Household earnings are measured and analyzed at the household level (8,579 households in Treatment PHAs and 3,166 in Control PHAs). Household earnings track the average earnings of households receiving housing subsidies in a given year as of December 31, 2022. Thus, households that exited during 2022 are not included, and households that entered during 2022 are included. A low-poverty census tract is defined as a census tract with a poverty rate of less than 10 percent or a poverty rate in the lowest quartile of census tract poverty rates for the PHA’s jurisdiction. The 2019 American Community Survey (ACS) 5-year data were used to be consistent with baseline measures, as both the census tract boundaries (2010 boundaries compared with 2020 boundaries) and the poverty rates for a given census tract changed over time. The unit of analysis for the percentage of households living in a low-poverty census tract is households (11,675 HCV households in the Treatment PHAs and 4,123 HCV households in the Control PHAs). Appendix D summarizes the methodology for arriving at the impact estimates. Financial data include Special Purpose Vouchers Sources: HUD’s Financial Data System (PHA annual fiscal reports through December 2022); HUD household-level data from the Housing Information Portal through December 31, 2022; 2021 ACS 5-year data 5.1.2 Self-Sufficiency

The MTW statutory objective related to self-sufficiency is “to give incentives to families with children where the head of household is working, seeking work, or is preparing for work by participating in job training, educational programs, or programs that assist people to obtain employment and become economically self-sufficient.” 58 For this evaluation, the self-sufficiency outcome is best measured as household earnings in a year. In keeping with an understanding of the MTW Waivers designed to encourage employment and earnings, the confirmatory outcome focuses on earnings of nonelderly, nondisabled households. Nonelderly, nondisabled households are those in which neither the head of household nor the spouse or co-head of household is aged 62 or older or has a disability. Earnings for all working-age residents in these households are summed to compute household earnings. 59 All nonelderly, nondisabled households are included in the household-level analysis. The data for earnings are from the National Directory of New Hires, which provides quarterly wage information on individual employees from state workforce agency and federal agency records.

58 Omnibus Consolidated Rescissions and Appropriations Act of 1996 (1996 Act).

59 For household earnings measures, “working age” is considered aged 14 (the minimum set by the Fair Labor Standards Act) to aged 61 (inclusive) at the end of 2021, the year National Directory of New Hires data are available for this report. For individual-level earnings measures, the outcomes are limited to residents aged 18 to 61. In Year 2, nonelderly, nondisabled households in the Treatment PHAs had statistically significant higher average annual earnings than similar households in the Control PHAs— $23,944 compared with $21,466, a difference of $2,478 (exhibit 5-3). However, no statistically significant differences were observed in average annual earnings between the Treatment PHAs and the Comparison PHAs. This differing result between the experimental and quasi-experimental comparison raises the question of whether the statistically significant finding in the experimental analysis is due to chance.

Additional supporting evidence that this finding could be due to chance is that the implementation of MTW activities is at an early stage. As discussed previously, very few approved waivers were implemented in 2022, so the use of those waivers does not seem to explain how this impact on earnings could arise.

Another potential explanation for estimating statistically significant effects in the experimental analysis but not the quasi-experimental analysis relates to sample size and sampling: the Control group contains only 10 PHAs, whereas the Comparison group contains 99 PHAs. Although random assignment resulted in the Treatment and Control groups being similar in observable characteristics at baseline, the average earnings of the Control group were slightly lower at baseline and increased at a slightly slower pace over the next 2 years compared to the Treatment and Comparison groups, as exhibit 5-4 shows. The slight differences at baseline and in trends after baseline suggest that the difference between Treatment and Control PHA earnings in 2022 is likely independent of the opportunity to apply for MTW designation.

Exhibit 5-4. Quarterly Earnings Over Time for Households in Treatment, Control, and Comparison Public Housing Agencies

Q1 = first quarter. Q2 = second quarter. Q3 = third quarter. Q4 = fourth quarter. Notes: The bands surrounding each indicate a 95 percent confidence interval. Areas for which confidence intervals do not overlap are quarters in which the between-group differences (impact) are considered statistically significant. Source: National Directory of New Hires, with authors’ computations of data

Next, the sample within each group—Treatment, Control, Comparison—changes over time, and compositional changes could be another reason for the observed impacts; that is, Treatment PHAs could be taking in a different type of resident, whether systematically in anticipation of fuller MTW implementation or by chance. In supplemental analyses (not shown), holding the sample constant—to those residents within any one of the years—results in the Treatment versus Control change in earnings not being statistically significant. Indeed, in Treatment PHAs, the new sample has higher earnings than the Control PHA’s new sample.

A final reason this finding could be due to chance is that statistically significant impacts were not observed for any of the exploratory self-sufficiency outcomes, as section 5.2 elaborates.

Trends in earnings and other self-sufficiency outcomes continue to be monitored, including using the process study and conducting supplemental analyses to consider explanations that point to whether the intervention or chance accounts for the changes. Next year’s impact analysis is anticipated to reveal whether the impact on 2022 earnings persists or grows along with fuller implementation of MTW activities. 5.1.3 Housing Choice

The MTW statutory objective related to housing choice is “to increase housing choices for low-income families.” 60 For this evaluation, that outcome is measured as living in higher quality neighborhoods defined as “low poverty.” As a result, the confirmatory outcome is computed as the percentage of HCV households in a PHA that live in a low-poverty census tract. A low-poverty census tract is one where the poverty rate is in the lowest quartile of census tracts within the PHA’s jurisdiction or where the poverty rate is less than 10 percent. 61 The outcomes and impacts for this measure are at the household level and are separately averaged for all households within Treatment PHAs and all households within Control PHAs.

The HCV households in the Treatment PHAs were more likely to reside in low-poverty census tracts than were HCV households in the Control PHAs (33 percent compared with 31 percent; exhibit 5-3). In the corresponding quasi-experimental analysis, the sample size was larger (16,408 households in 2022; 16,328 households at baseline), but the estimated program impact was not statistically significant. This combination of results—observing statistically

60 Omnibus Consolidated Rescissions and Appropriations Act of 1996 (1996 Act).

61 For this evaluation, the definition of “low poverty” is based on the neighborhood poverty rate because it is a readily available measure associated with children’s future outcomes (Galster et al., 2007). To estimate the PHA’s lowest quartile of poverty rate, the census tracts that comprise the jurisdiction are first identified. All census tracts where at least 2 percent or 5 or more (whichever is smaller) of a PHA’s households live and all census tracts

neighboring those census tracts are included. This rule for defining a “jurisdiction” has changed since the Research Design / Data Collection and Analysis Plan . The previous definition used only the “2 percent of households” inclusion threshold for the first set of census tracts. Now, the inclusion threshold includes “or five or more households,” which permits the inclusion of more census tracts for PHAs with more than 250 households. Census

tracts are not weighted equally when constructing the poverty rate distribution in each jurisdiction. To focus on renters, census tract poverty rates are weighted by the number of renter households (rather than owner) living in the census tract. This choice results in a better reflection of the neighborhood choices for renters for that jurisdiction. significant impact in the experimental but not the quasi-experimental analysis—again raises the question of whether this finding is due to chance alone.

Program effects on housing choice seem unlikely because MTW implementation for Flexibility Cohort PHAs was still in the very early stages in 2022. Although many Treatment PHAs are approved to implement activities to increase housing choice that could lead to more voucher households in low-poverty census tracts, very few PHAs started implementing those activities in 2022. It is likely that the positive impact observed in the experimental analysis reflects the ongoing trends in the Treatment and Control groups rather than the impact of the MTW intervention. From baseline to Year 2, the percentage of households in low-poverty areas in the Treatment PHAs was relatively constant, whereas the rates in the Control PHAs decreased. Unfortunately, it is difficult to discern the driver of the trends with the available information.

Finally, as with the estimated impacts for the self-sufficiency outcome, these findings may be due to chance because none of estimated effects for the exploratory housing choice outcomes were statistically significant. Future impact analyses are expected to reveal whether the impact on the share of households living in a low-poverty census tract, as measured in 2022, persists or grows along with the fuller implementation of MTW activities in future years. 5.2 Exploratory Outcomes

Appendix C provides impact estimates for 62 exploratory outcomes. Several statistically significant differences are estimated, which could be due to chance rather than the effect of MTW. Any statistically significant findings are expected to be due to chance alone because MTW activities implementation is still in a very early stage. Therefore, to limit attention to results that could be due to chance alone, any statistically significant impact is only highlighted if it also arises in the quasi-experimental (Treatment versus Comparison PHAs) analysis. If the impact is statistically significant in both the experimental and quasi-experimental analysis, the following briefly summarizes it, with speculation about whether it could be due to MTW activities.

• For cost-effectiveness, the experimental analysis of the exploratory outcomes shows that the Treatment PHAs compared with the Control PHAs have (1) higher total revenue in a measure that combines HUD funding of HAP costs, public housing operating subsidies, public housing capital grants, management, bookkeeping fees, other government grants, and investment income; and (2) higher costs in a measure that combines HCV administrative costs and the total costs of LNT programs (exhibit C-1). These findings are comparable with the quasi-experimental (Treatment versus Comparison PHAs) analysis. Higher administrative costs among the Treatment PHAs could reflect the costs of starting up MTW activities. The impact estimate controls for baseline differences in this measure between the Treatment and Control PHAs. Therefore, it is difficult to explain why total revenues is higher for the Treatment PHAs. 62

• Only one of the eight impact estimates is statistically significant for housing choice measures related to the housing available to voucher households. Treatment PHAs have more

62 At baseline, Treatment PHAs had higher revenue than Control PHAs ($748 per unit month compared with $645).

At baseline, Treatment PHAs also had higher administrative and tenant services expenditures than Control PHAs ($79 per unit month compared with $54 per unit month). Controlling for baseline levels also controls for geographic differences in cost, as long as those geographic differences remain constant over time.

unique landlords per 100 HCV households than the Control PHAs, even after controlling for baseline differences (exhibit C-4). These findings are replicated in the quasi-experimental (Treatment versus Comparison PHAs) analysis (not shown). Given how few MTW activities were implemented in 2022, this finding seems likely due to chance rather than MTW.

• The rent burden of public housing residents who are not paying minimum rent is slightly lower in the Treatment PHAs households than in the Control PHAs. 63 Public housing residents in the Treatment PHAs pay 28 percent of their income on average, compared with 29 percent in the Control PHAs, implying that public housing residents in the Treatment PHAs receive somewhat greater deductions from gross income (exhibit C-8). These impacts are also evident in the quasi-experimental (Treatment versus Comparison PHAs) analysis. This finding could change once MTW activities are fully implemented because some Treatment PHAs are changing their policies on deductions from income.

At the same time, the Treatment PHAs served fewer households that pay minimum rent than the Control PHAs (3 versus 5 percent; exhibit C-8). This finding could also change when MTW activities are fully implemented because some Treatment PHAs are increasing minimum rents, making them applicable to additional households.

Among these 62 exploratory outcomes, impact estimates for 5 outcomes are statistically significant both in the experimental (Treatment versus Control PHAs) analysis and in the quasi-experimental (Treatment versus Comparison PHAs) analysis: (1) total revenue per unit month; (2) HCV and LNT program administrative and tenant service expenditures per household per month; (3) the number of unique landlords per 100 HCV households; (4) the rent burdens of public housing residents; and (5) the proportion of public housing residents who pay minimum rent. Statistically significant estimates for five out of 62 outcomes are fewer than is expected by chance alone (corresponding to p-values of 0.10 or less, meaning that at least 10 percent, or 6 of 62, is expected to be statistically significant due to chance alone). In addition, these results from the exploratory analysis do not provide further insights into the results of the confirmatory analysis. Therefore, it is not advisable to allocate too much weight to the statistically significant estimates for these 5 exploratory outcomes. The overall conclusion is that it is too early to expect to observe impacts from MTW activities.

Finally, in the two domains, self-sufficiency and housing choice, in which the estimated impacts on confirmatory outcomes are statistically significant, none of the estimated impacts on the exploratory outcomes examined in those domains are statistically significant in both the experimental (Treatment versus Control PHAs) and quasi-experimental (Treatment versus Comparison PHAs) analysis. This observation underscores the possibility that the confirmatory findings could be due to chance. Impact analysis in future years is expected to reveal whether these early findings persist as MTW implementation matures over time.

63 Public housing residents paying minimum rent were excluded because they frequently have zero income, effectively having a rent burden of infinity. 6. Summary of Findings for Research Questions

This chapter discusses the findings for the two overarching research questions for the Flexibility Cohort in 2022, the second year after being offered the opportunity to become a Moving to Work (MTW) public housing agency (PHA). This chapter starts with the findings for the process study question and follows with the findings for the impact study question. 6.1 How Do Smaller Public Housing Agencies Use Moving to Work Flexibility?

Flexibility Cohort PHAs make robust use of MTW flexibility to make changes in their program, although they are very early in implementing the MTW activities. All except one PHA have received approval for multiple MTW Waivers, with some representing substantial departures from standard procedures. Most PHAs in this cohort did not only obtain approval for minor programmatic or administrative changes but combined several MTW Waivers in an overall strategy to improve their housing assistance programs.

PHAs have used less funding flexibility as part of their strategies thus far. About one-third (11) of the 31 Flexibility Cohort PHAs have used funding flexibility to support MTW activities by transferring funds among their public housing and housing choice voucher (HCV) funding streams. 6.1.1 Volume of Waiver Activity

All 31 Flexibility Cohort PHAs had MTW funding flexibility by early 2022, and 26 of the 31 PHAs had approved MTW Supplements with waivers allowing them to conduct activities that standard PHAs cannot. There are 236 approved waivers among the 26 PHAs.

• All but 1 of the 236 approved waivers are from the list of 70 preapproved waivers in the MTW Operations Notice (HUD, 2020).

o The single agency-specific waiver allows landlords to self-certify that the unit has no life-threatening emergencies for move in (with a Housing Quality Standards [HQS] inspection to be scheduled within 60 days of move-in).

• The median number of MTW Waivers is 8, with three PHAs having 20 or more approved waivers and three PHAs having 3 or fewer approved waivers.

• The most common waivers are for—

o Decreasing the frequency of income reexaminations (18 PHAs). o Increasing the value of assets that can be self-certified (14 PHAs). o Eliminating or reducing the number of utility reimbursements (11 PHAs). Adding financial incentives for landlords to participate in the HCV program (10 PHAs). o Increasing the minimum rent (nine PHAs). o o Streamlining the utility allowance schedule (nine PHAs).

6.1.2 Targeted Objectives

More than half of the 26 PHAs with approved MTW Supplements designed activities that addressed all three MTW statutory objectives. Cost-Effectiveness Objective

• Of the 26 PHAs with an approved MTW Supplement, all but 2 have a waiver for an administrative efficiency activity that reduces staff time and could improve cost-

effectiveness. Half of those 24 PHAs have approval for three or more such activities. The most commonly approved activities include—

o Biennial or triennial income reexaminations for any household type (18 PHAs). Self-certification of assets of as much as $25,000 or $50,000 (14 PHAs), including two o PHAs that also exclude asset income from rent calculations.

• Another approved administrative efficiency activity likely saving substantial staff time includes—

o Less frequent inspections for units (six PHAs) (usually limited to those with a good inspection history and an option for voucher households to ask for an inspection), including five PHAs with some units qualifying for triennial inspections.

Self-Sufficiency Objective

• Of the 26 PHAs with an approved Supplement, 20 PHAs have approved MTW activities addressing the self-sufficiency objective, including 12 PHAs with multiple such activities. The most commonly approved activities include—

o Decreasing reexaminations for nonelderly, nondisabled households (13 PHAs), including 4 PHAs with triennial reexamination. 64 Increasing the minimum rent (nine PHAs). o

• Other less frequent activities to encourage self-sufficiency with a substantial change from what a standard PHA can do include—

o A work requirement of at least 15 hours per week (four PHAs). o Mandatory MTW Self-Sufficiency program participation (four PHAs). o Financial incentives for meeting self-sufficiency goals (three PHAs), including one PHA paying a $500 bonus to households that continuously work full time for a year. A stepped rent that can increase independent of an income increase (three PHAs). o o A 5-year term limit for assistance, with 2 years of extension possible (one PHA).

Housing Choice Objective

• Of the 26 PHAs with an approved Supplement, 19 PHAs have approved MTW activities addressing the housing choice objective either by incentivizing landlords to participate or by expanding the number of units available for voucher holders in the HCV program, including 9 PHAs that have approval for both types of activities. The most common approved activities include—

o Financial incentives (10 PHAs), ranging from $250 to $1,000 for a new landlord or an existing landlord renting a new unit, including two PHAs that also have bonuses of $250 or $500 for referring a new landlord to the HCV program. 65

o A payment standard of 120 percent of Fair Market Rent (FMR; eight PHAs), expanding the number of units available to voucher holders. 66

64 Other PHAs have less frequent reexaminations only for households on fixed incomes.

65 Two PHAs are offering bonuses to new landlords of up to 1 month of contract rent, which could exceed $1,000. 66 One PHA that has an approved waiver to increase the payment standard to 110 percent of FMR is not included here because a standard PHA can do that. In addition, nine PHAs have approved waivers to do nonstandard activities through the Short-Term Assistance or the LNT activities waiver categories. These waivers allow PHAs to serve either or both their own assisted households and other low-income households in their community outside the standard public housing and HCV programs. Five of the PHAs approved for LNT activities are looking to expand the pool of affordable housing in their community. Three PHAs have waivers to provide self-sufficiency services not otherwise permitted for non-MTW PHAs. Examples of the planned activities include—

• Supporting development of supportive housing for youth aging out of foster care. Making improvements to a PHA-owned building and adding project-based vouchers (PBVs) • to the site. Providing support for eight occupants of a transitional housing facility. • Providing 12 months of emergency assistance to households experiencing homelessness. •

6.2 What Are the Impacts of Moving to Work Flexibility on Smaller Public Housing Agencies and Their Residents?

As of this 2022 followup, a statistically significant impact on the confirmatory cost-effectiveness outcome—PHA per-household monthly expenditure—was not detected.

Statistically significant impacts on the confirmatory self-sufficiency—annual household earnings—and housing choice —share of HCV households in low-poverty census tracts— outcomes were detected. However, for the reasons chapter 5 details, one or both of those findings are believed to be likely due to chance.

The evaluation continues for 2 more years. More Flexibility Cohort PHAs are expected to begin implementing their approved MTW activities in 2023 and 2024, and PHAs that have already begun are anticipated to implement more activities. In early 2023 interviews with PHA staff, 10 additional PHAs reported they had started implementing activities in the second half of 2022 and 5 additional PHAs in the first quarter of 2023, which means that 22 Flexibility Cohort PHAs are expected to have implemented at least one activity for all or most of 2023.

Appendix A. Maps of Moving to Work Flexibility Cohort Public Housing Agencies and Control Public Housing Agencies

This appendix shows the geographic distribution of the Flexibility Cohort public housing agencies (PHAs) and Control PHAs (exhibits A-1 and A-2).

Exhibit A-1. Map of 31 Moving to Work Flexibility Cohort Public Housing Agencies

Notes: “Combined units” are the total of housing choice voucher and public housing units from 2019 Picture of Subsidized Households. Public housing agencies are labeled in metropolitan statistical areas as defined by the U.S. Census Bureau (an area with relatively high population density of social and economic

integration as determined by commuting patterns). For more information, see https://www.census.gov/programs-surveys/metro-micro/about/omb-standards.htm.

63

Exhibit A-2. Map of 10 Control Group PHAs (Numbered) Relative to Flexibility Cohort PHAs (not Numbered)

Notes: “Combined units” are the total of housing choice voucher and public housing units from 2019 Picture of Subsidized Households. PHAs are labeled in metropolitan statistical areas as defined by the U.S. Census Bureau (an area with relatively high population density of social and economic integration as

determined by commuting patterns). Treatment PHA locations are the unnumbered house symbols. For more information, see https://www.census.gov/programs-surveys/metro-micro/about/omb-standards.htm. Control Group PHAs are numbered and Flexibility Cohort PHAs are not numbered in this map.

64

Appendix B. Profiles for 26 Flexibility Cohort Public Housing Agencies with Approved Moving to Work Supplements

Appendix B exhibits provide information on each of the 26 Flexibility Cohort public housing agencies (PHAs) with an approved Moving to Work (MTW) Supplement as of March 31, 2023. The PHAs are listed alphabetically based on their PHA code. The tables present information on each PHA in two parts: Part (a) of each exhibit provides background information on the PHA, including the MTW Supplement(s) approval date, total number of waivers approved, program types operated, and number of units the PHA operates. Part (b) of each exhibit provides information on approved MTW activities for the PHA to implement, statutory objectives the activity aims to meet, and anticipated effect on PHA costs. The information in part (b) is classified as reported by the PHA and pulled from the PHA’s most recently approved MTW Supplement (as of March 31, 2023). In some cases, PHAs classified anticipated costs in unexpected ways. For example, a PHA indicated that offering landlord incentives would be cost-neutral for the PHA. Exhibit B-1(a). Background Information for Sheffield Housing Authority

Location Sheffield, Alabama ACC Amendment March 2021 Approval

Programs and HCV: 338 units MTW Supplement FY2021: October 2021 Inventory Approvals Public Housing: 406 FY2022: November units 2022

Special Purpose Mainstream Total MTW Waivers 3 Vouchers Approved RAD Conversion No Use of PBVs No

ACC = Annual Contributions Contract. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. SOURCES: MTW Supplements; interview with PHA in February 2023; HUD communications

Exhibit B-1(b). Approved MTW Waivers as of March 31, 2023, for Sheffield Housing Authority (AL-068)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent Utility reimbursements will no longer be Cost-Effectiveness Positive Policies: Utility offered to residents if the utility (Increased Self-Sufficiency Reimbursements allowance is greater than the total revenue and for PH (1.m.) tenant payment. This policy will not be decreased applied to elderly or disabled expenditures) Tenant Rent households. Policies: Utility

Reimbursements for HCV (1.n.)

Landlord Landlords will receive an incentive Housing Choice Negative Incentives: Other equal to the contract rent or $500 (Increased

Landlord (whichever is less) for each new unit expenditures) Incentives for leased to an HCV tenant. The payment HCV, Tenant-will be made to the landlord when the Based Assistance Housing Assistance Payment (HAP)

(4.c.) contract is executed.

HCV = housing choice voucher. MTW = Moving to Work. PH = public housing. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in February 2023 Exhibit B-2(a). Background Information for Ozark Housing Community (AL-073)

Location Ozark, Alabama ACC Amendment March 2021 Approval

Programs and HCV: 434 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 393 FY2022: May 2022 units

Special Purpose None Total MTW Waivers 5 Vouchers Approved RAD Conversion No Use of PBVs No

ACC = Annual Contributions Contract. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. Sources: MTW Supplements; interview with PHA in March 2023; HUD communications

Exhibit B-2(b). Approved MTW Waivers as of March 31, 2023, for Ozark Housing Community (AL-073)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent The minimum rent will increase from Cost-Effectiveness Positive Policies: Minimum $50 to $130 for all nonelderly, (Increased Self-Sufficiency Rent for PH (1.e.) nondisabled public housing households. revenue and decreased

expenditures)

Tenant Rent The utility reimbursement will still be Cost-Effectiveness Positive Policies: Utility applied to the total tenant payment, but (Decreased Self-Sufficiency Reimbursements it will be capped so that the tenant expenditures) for PH (1.m.) payment cannot be less than $0.

Family Self- The Ozark Housing Community will Self-Sufficiency Neutral

Sufficiency (FSS) waive operating a required FSS program with program that has been defunct for more MTW Flexibility: than 10 years. Waive Operating a

Required FSS program for HCV (10.a.)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Work Requirement Each family member aged 19 to 61 will Self-Sufficiency Positive for PH (12.a.) be required to be employed a minimum (Increased of 15 hours per week (30 hours per Revenue) Work Requirement week minimum for households with for HCV (12.b.) multiple eligible members) or meet a qualifying work activity. Participants who do not comply with the work requirement will be subject to

termination of housing assistance after a 6-month notice. Elderly and disabled households are excluded from this activity.

HCV = housing choice voucher. MTW = Moving to Work. PH = public housing. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in March 2023 Exhibit B-3(a). Background Information for Pomona Housing Authority (CA-123)

Location Pomona, California ACC Amendment June 2021 Approval

Programs and HCV: 982 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 0 units FY2022: March 2022

Special Purpose EHV, FYI, Mainstream, Total MTW Waivers 8 Vouchers VASH Approved RAD Conversion No Use of PBVs Yes

ACC = Annual Contributions Contract. EHV = Emergency Housing Vouchers. FY = fiscal year. FYI = Foster Youth to Independence. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. VASH = Veterans Affairs Supportive Housing. Sources: MTW Supplements; interview with PHA in February 2023; HUD communications

Exhibit B-3(b). Approved MTW Waivers as of March 31, 2023, for Pomona Housing Authority (CA-123)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent One streamlined utility allowance will Cost-Effectiveness Neutral Policies: apply to all HCV units based on

Alternative Utility bedroom size and types of utilities Allowance for participants pay in the city of Pomona. HCV (1.j.) The PHA will continue to review its utility allowance schedule each year

and revise it if a 10-percent change occurs from the prior year. This update is a change from the former utility allowance based on utility surveys and

analysis of the structure type, bedroom size, tenant-provided appliances, and type of appliances (gas or electric).

Tenant Rent Utility reimbursement payments will be Cost-Effectiveness Positive Policies: Utility eliminated. Families will continue to (Decreased

Reimbursements receive a utility allowance but no Costs and for HCV (1.n.) additional money if the utility allowance Increased is greater than the total tenant payment. Revenue)

Tenant Rent Existing deductions used during the rent Cost-Effectiveness Positive Policies: Standard calculation process will be replaced with (Increased

Deductions for a standard deduction of $500 for elderly Revenue) HCV (1.u.) and disabled families and nonelderly families with one or more dependents (children younger than 18, a disabled

household member, or a full-time student in the household).

Reexaminations: Reexaminations will move from an Self-Sufficiency Neutral (No cost Alternative annual to a biennial schedule for all implications) Reexamination HCV residents with at least $1,200 per

Schedule for year in annual income. Any families Households for reporting less than $1,200 per year in HCV (3.b.) annual income will remain on an annual

recertification cycle.

Reexaminations: HCV residents will be allowed to self- Self-Sufficiency Positive Self Certification certify up to $50,000 in assets during (Decreased of Assets for HCV the reexamination process. Prior to this expenditures) (3.d.) change, residents were not allowed to

self-certify any assets.

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Landlord Leasing Landlords will be allowed to submit Housing Choice Negative Incentives: damage claims of up to one month’s (Increased Damage Claims contract rent (minus any amounts paid Expenditures) for HCV (4.b.) in security deposit) for damages beyond

normal wear and tear to units HCV recipient rent. Damage claim payments will be paid to landlords when the next HAP contract is executed between the owner and PHA.

Landlord Leasing A one-time $250 signing bonus will be Housing Choice Negative Incentives: Other given to landlords for each new HAP (Increased Landlord contract executed in the city of Pomona. Expenditures) Incentives for HCV

(4.c.)

Local, MTW funding flexibility will be used to Housing Choice Negative nontraditional acquire, renovate, or build nonpublic (Increased Activities: Housing housing affordable units. Activities may Expenditures) Development include gap financing for non-PHA

Programs (17.c) development of affordable housing and project-based voucher units or tax-credit partnerships. HAP = Housing Assistance Payment. HCV = Housing Choice Voucher. MTW = Moving to Work. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in February 2023 Exhibit B-4(a). Background Information for Solano County Housing Authority (CA-131)

Location Vacaville, California ACC Amendment April 2021 Approval

Programs and HCV: 290 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 0 units FY2022: July 2022

Special Purpose Mainstream, VASH Total MTW Waivers 8 Vouchers Approved RAD Conversion No Use of PBVs Yes

ACC = Annual Contributions Contract. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. VASH = Veterans Affairs Supportive Housing. Sources: MTW Supplements; interview with PHA in February 2023; HUD communications

Exhibit B-4(b). Approved MTW Waivers as of March 31, 2023, for Solano County Housing Authority (CA-131)

Waiver Statutory Anticipated Effect Description of Planned Change Objectives on PHA Costs Targeted

Tenant Rent The maximum share of a family’s Housing Choice Neutral (No cost Policies: Initial adjusted monthly income that can be implications)

Rent Burden for used toward rent will increase from HCV (1.o.) 40 to 50 percent at initial lease up.

Reexaminations: Annual reexaminations will become Cost- Positive (Decreased Alternative triennial for families for whom at Effectiveness expenditures) Reexamination least 90 percent of income is from a

Schedule for fixed source. Households for HCV (3.b.)

Reexaminations: The value of family assets and Cost- Positive (Decreased Self Certification anticipated asset income that can be Effectiveness expenditures)

of Assets for HCV self-certified at reexamination will (3.d.) increase to $50,000. All assets valued more than $50,000 will continue to require third-party

verification.

Landlord Leasing Landlords participating in the HCV Housing Choice Negative (Increased Incentives: program will be eligible to receive expenditures) Vacancy Loss vacancy loss payments up to 1 (4.a.) month of contract rent for PHA-

related lease-up delays between prior voucher and new voucher households.

Landlord Leasing If an HCV resident leaves damages Housing Choice Negative (Increased Incentives: to a rental unit beyond normal wear expenditures)

Damage Claims and tear, the landlord will be able to (4.b.) request a damage claim for up to 2 months’ contract rent.

Landlord Leasing Landlords who rent units to voucher Housing Choice Negative (Increased

Incentives: Other holders that an HCV resident has expenditures) Landlord not occupied in the previous 12 Incentives (4.c.) months will be eligible for an incentive of 1 month’s contract rent.

Housing Quality SCHA will offer prequalifying unit Housing Choice Neutral (No cost

Standards: inspections (also known as a pre- implications) Prequalifying Unit inspection) on vacant units ready for Inspections for occupancy by request. Inspections HCV (5.a.) will be valid for 90 days.

Project-Based Housing options for veterans Housing Choice Negative (Increased

Voucher (PBV) experiencing homelessness will be expenditures) Program increased in the PHA’s jurisdiction

Waiver Statutory Anticipated Effect Description of Planned Change Objectives on PHA Costs Targeted

Flexibilities: by implementing a PBV program for Alternative PBV shared housing. Unit Types (9.e.) HCV = Housing Choice Voucher. MTW = Moving to Work. PHA = public housing agency. SCHA = Solano County Housing Authority. Sources: MTW Supplement; interview with PHA in February 2023 Exhibit B-5(a). Background Information for Brighton Housing Authority (CO-019)

Location Brighton, Colorado ACC Amendment June 2021 Approval

Programs and HCV: 251 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 0 FY2022: October 2022

Special Purpose None Total MTW Waivers 12 Vouchers Approved

RAD Conversion Yes (portfolio to PBV) Use of PBVs Yes

ACC = Annual Contributions Contract. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. Sources: MTW Supplements; interview with public housing agency in February 2023; HUD communications

Exhibit B-5(b). Approved MTW Waivers as of March 31, 2023, for Brighton Housing Authority (CO-019)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent Policies: Utility allowance schedules will be Cost- Neutral (no cost

Alternative Utility consolidated from four to two to Effectiveness implications) Allowance (1.j.) simplify and to reduce the possibility of administrative errors in applying the wrong schedule, resulting in

subsidy under- or overpayment.

Tenant Rent Policies: Utility reimbursements will no longer Cost- Positive Utility be issued if the utility allowance Effectiveness (Decreased Reimbursements exceeds the total tenant payment. expenditures) Self-Sufficiency (1.n.)

Tenant Rent Policies: A partial income exclusion will apply Self-Sufficiency Negative

Alternative Income to household members aged between (Increased Inclusions/Exclusions 18 and 30 who are not a household expenditures) (1.w.) head, so only 75 percent of their earned income is used when

calculating a family’s total tenant payment.

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Payment Standards The PHA will no longer ask a third Cost- Positive and Rent party to review and approve the rent Effectiveness (Decreased Reasonableness: reasonableness for properties the expenditures) Third-Party PHA owns, controls, or manages.

Requirement (2.d.)

Reexamination: Elderly and disabled households will Cost- Negative Alternative move from an annual to a triennial Effectiveness (Decreased Reexamination reexamination schedule. revenue) Schedule for

Households (3.b.)

Reexamination: Self Households will be allowed to self- Cost- Positive Certification of certify up to $25,000 in assets at Effectiveness (Decreased Assets (3.d.) reexamination. expenditures)

Housing Quality The PHA will now conduct HQS Cost- Positive Standards (HQS): inspections for units the PHA owns, Effectiveness (Decreased

Third-Party controls, or manages. expenditures) Housing Choice Requirement (5.c.)

Project-Based The percentage of units that can be Housing Choice Negative Voucher (PBV) project-based will be increased to up (Increased Program Flexibilities: to 50 percent of total authorized units expenditures)

Increase PBV or annual budget authority. Program Cap (9.a.)

PBV Program The cap on the percentage of PBVs Housing Choice Negative Flexibilities: Increase that can be project based in a building (Increased PBV Project Cap or project will be increased from 25 to expenditures)

(9.b.) 100 percent.

PBV Program The PHA will eliminate the selection Housing Choice Positive Flexibilities: process in awarding PBVs to (Decreased Elimination of PBV nonpublic housing properties the expenditures)

Selection Process for agency owns. The PHA has PHA-owned Projects historically had extremely limited Without responses to the PBV selection Improvement, process. Having a reliable,

Development, or knowledgeable developer increases Replacement of the likelihood of projects coming to Public Housing Site fruition, returning a bit of leverage to (9.c.) the PHA over a selection process with

only one applicant.

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

PBV Program Portability will be limited by delaying Cost- Neutral (no cost Flexibilities: Limit when a household can request to Effectiveness implications) Portability for PBV move from a PBV to a tenant-based Housing Choice Units (9.h.) voucher. Households must now have

been in the PBV unit for 2 years instead of 1 before requesting a tenant-based voucher.

Local, Nontraditional The PHA will allocate up to $145,000 Self-Sufficiency Negative Activities : Service of Housing Assistance Payment (Increased Housing Choice Provision (17.b.) funding to support the following or expenditures) similar programs:

• Housing Navigation.

• Career and College Launch.

• Domestic Violence Emergency Shelter.

• Food Assistance.

• Technology Library Program.

• Tenant-Based Rental Assistance.

• Case Management.

• Vaccine Clinics.

• Youth Tutoring.

MTW = Moving to Work. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in February 2023 Exhibit B-6(a). Background Information for the New Smyrna Beach Housing Authority (FL-022)

Location New Smyrna Beach, ACC Amendment April 2021 Florida Approval

Programs and HCV: 288 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 126 FY2022: September

units 2022

Special Purpose Mainstream, VASH Total MTW Waivers 17 Vouchers Approved

RAD Conversion No Use of PBVs No, but planned.

ACC = Annual Contributions Contract. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. VASH = Veterans Affairs Supportive Housing.

Sources: MTW Supplements; interview with PHA in February 2023; HUD communications

Exhibit B-6(b). Approved MTW Waivers as of March 31, 2023, for the New Smyrna Beach Housing Authority (FL-022)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent Policies: The minimum rent for nonelderly and Cost- Positive Minimum Rent for nondisabled households will increase Effectiveness (Increased

PH (1.e.) from $50 to $130 per month. revenue, Self-Sufficiency Decreased Tenant Rent Policies: expenditures) Minimum Rent for HCV (1.f.)

Tenant Rent Policies: A standard utility allowance will be Cost- Positive

Alternative Utility used for public housing and HCV Effectiveness (Increased Allowance for PH households. The PHA created two revenue, Self-Sufficiency (1.i.) standard utility allowance schedules Decreased based on bedroom size and dwelling expenditures) Tenant Rent Policies: type (multifamily or single-family) for Alternative Utility HCV and one standard utility Allowance for HCV allowance schedule based on (1.j.) bedroom size for public housing.

Tenant Rent Policies: Utility reimbursements will be Cost- Positive

Utility eliminated for all households. Effectiveness (Increased Reimbursements for revenue, PH (1.m.) Decreased expenditures) Tenant Rent Policies:

Utility Reimbursements for HCV (1.n.)

Tenant Rent Policies: The PHA will eliminate dependent Cost- Positive Elimination of allowance, unreimbursed childcare Effectiveness (Increased

Deductions for PH costs, and disability assistance revenue, (1.r.) deductions from consideration when Decreased determining total tenant payment for expenditures) Tenant Rent Policies: able-bodied households. Elimination of

Deductions for HCV (1.s.)

Tenant Rent Policies: The Earned Income Disregard will be Cost- Positive Alternative Income eliminated. Households will still Effectiveness (Decreased

Inclusions/Exclusions benefit from an increase in income expenditures) Self-Sufficiency for PH (1.v.) without an immediate increase in rent due to triennial recertifications Tenant Rent Policies: (waivers 3a and 3b). Alternative Income

Inclusions/Exclusions for HCV (1.w.)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Payment Standards: The payment standard will be Housing Choice Negative Fair Market Rents increased from 110 to 120 percent of (Decreased (FMR) for HCV (2.b.) FMR. A 120-percent payment revenue) standard of FMR will increase the

payment standard by an average of $118 for all bedroom sizes.

Reexaminations: The frequency of reexaminations will Cost- Positive Alternative decrease from annual to triennial for Effectiveness (Decreased Reexamination all public housing and HCV expenditures) Self-Sufficiency Schedule for households. Interim recertifications Households for PH will be limited to one per calendar (3.a.) year at the request of the household. If the interim recertification is for a Reexaminations: decrease in income, only income Alternative decreases of 10 percent or more will Reexamination be processed. Interim decreases Schedule for during the first 6 months after initial Households for HCV occupancy are not allowed. Required (3.b.) interim recertifications for household composition changes will not count

against the limit on voluntary interim recertifications.

Reexaminations: Self The PHA will increase the threshold Cost- Positive Certification of for the self-certification of assets from Effectiveness (Decreased Assets for PH (3.c.) $5,000 to $25,000. expenditures)

Reexaminations: Self

Certification of Assets for HCV (3.d.)

Housing Quality The inspection schedule for all HCV Cost- Positive Standards: units will move to a triennial Effectiveness (Increased Alternative frequency. HCV participants will be revenue,

Inspection Schedule allowed to request an interim Decreased for HCV (5.d.) inspection, and HUD may conduct or expenditures) direct the PHA to perform an

inspection at any time.

PBV Program The cap on the percentage of PBVs Cost- Positive Flexibilities: Increase that can be project based in a building Effectiveness (Increased PBV Project Cap for or project increased from 25 to 100 revenue) Housing Choice HCV (9.b.) percent. HCV = Housing Choice Voucher. MTW = Moving to Work. PBV = Project-Based Voucher. PH = public housing. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in February 2023 Exhibit B-7(a). Background Information for the Housing Authority of Newnan (GA-095)

Location Newnan, Georgia ACC Amendment August 2021 Approval

Programs and HCV: 85 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 439 FY2022: July 2022 units

Special Purpose FUP, Mainstream Total MTW Waivers 11 Vouchers Approved RAD Conversion No Use of PBVs No

ACC = Annual Contributions Contract. FY = fiscal year. FUP = Family Unification Program. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. Sources: MTW Supplements; interview with PHA in February 2023; HUD communications

Exhibit B-7(b). Approved MTW Waivers as of March 31, 2023, for the Housing Authority of Newnan (GA-095)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent The minimum rent will be increased from Cost- Positive Policies: Minimum $50 to $130 for all nonelderly, Effectiveness (Increased Rent for PH (1.e.) nondisabled households. Full-time revenue) Self-Sufficiency students will be exempt from this Tenant Rent change. Policies: Minimum Rent for HCV (1.f.)

Tenant Rent Utility reimbursements will be eliminated. Cost- Neutral (no cost Policies: Utility Elderly, disabled, and full-time student Effectiveness implications)

Reimbursements households will be exempt from this Self-Sufficiency for PH (1.m.) change.

Tenant Rent Policies: Utility

Reimbursements for HCV (1.n.)

Tenant Rent The childcare deduction used in Cost- Neutral (no cost Policies: determining total tenant payment will be Effectiveness implications)

Elimination of capped to match with the Georgia Deductions for PH Childcare and Parent Services (GA (1.r.) CAPS) reimbursement amounts. Childcare deductions will not exceed GA Tenant Rent CAPS reimbursement amounts and are Policies: reduced to categorical maximum Elimination of amounts filtered by age. Deductions for HCV (1.s.)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Reexaminations: The reexamination schedule will be Cost- Neutral Alternative revised to occur biennially for nonelderly, Effectiveness (increased Reexamination nondisabled households and triennially expenditures and Schedule for for elderly or disabled households. A decreased

Households for hardship interim recertification may be expenditures) PH (3.a.) requested between biennial recertifications if the household gross Reexaminations: income decreased 10 percent or more. Alternative Elderly and disabled households are Reexamination exempt from this provision and can Schedule for complete an interim recertification at any Households for time. HCV (3.b.)

Landlord Leasing Landlords will be eligible for a one-time Housing Choice Neutral (no cost

Incentives: claim reimbursement of up to $1,000 for implications) Damage Claims damages left to a unit by an HCV for HCV (4.b.) household. The amount of damage claims will not exceed $1,000 or lesser of

the cost of repairs.

Landlord Leasing Landlords will receive a one-time signing Housing Choice Neutral (no cost Incentives: Other bonus of up to $1,000 for renting a new implications) Landlord unit (not previously rented by an HCV Incentives for HCV recipient) to an HCV recipient. Landlords

(4.c.) can receive the bonus once each year when they rent a new unit to an HCV recipient.

Local, The PHA will provide housing units for Housing Choice Neutral (no cost Nontraditional transitional housing to assist the implications)

Programs: Service homeless population of Newnan and Provision (17.b.) Coweta County. One transitional housing facility will be available to house eight occupants, including women and

children.

HCV = Housing Choice Voucher. MTW = Moving to Work. PH = public housing. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in February 2023

Exhibit B-8(a). Background Information for the Housing Alliance and Community Partnerships (ID-005)

Location Pocatello, Idaho ACC Amendment March 2021 Approval

Programs and HCV: 714 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 72 units FY2022: June 2022

Special Purpose EHV, FYI, Mainstream, Total MTW Waivers 24 Vouchers VASH Approved

RAD Conversion No Use of PBVs No, but planned.

ACC = Annual Contributions Contract. EHV = Emergency Housing Vouchers. FY = fiscal year. FYI = Foster Youth to Independence. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. VASH =Veterans Affairs Supportive Housing. Sources: MTW Supplements; interview with PHA in February 2023; HUD communications

Exhibit B-8(b). Approved MTW Waivers as of March 31, 2023, for the Housing Alliance and Community Partnerships (ID-005)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent Policies: The minimum rent amount for all Cost- Positive

Minimum Rent for nonelderly and nondisabled Effectiveness (Decreased PH (1.e.) households will increase to $127. expenditures) Self-Sufficiency Tenant Rent Policies: Minimum Rent for

HCV (1.f.)

Tenant Rent Policies: Total tenant payment as a percentage Cost- Negative Tenant Payment as of gross income will decrease from 30 Effectiveness (Increased a Modified to 27 percent when this amount is expenditures) Self-Sufficiency Percentage of higher than minimum rent ($127).

Income for PH (1.g.)

Tenant Rent Policies: Tenant Payment as a Modified

Percentage of Income for HCV (1.h.)

Tenant Rent Policies: The utility allowance will be simplified Cost- Neutral Alternative Utility to one standard utility allowance per Effectiveness (Increased

Allowance for PH bedroom size, regardless of tenant Expenditures and Housing Choice (1.l.) utility responsibility. The utility Decreased allowances will be determined by using Expenditures) Tenant Rent Policies: the average utility allowance per Alternative Utility number of bedrooms per unit and Allowance for HCV rounding to the nearest dollar. (1.j.)

Tenant Rent Policies: Utility reimbursement payments will be Cost- Positive Utility eliminated. Families will continue to Effectiveness (Decreased Reimbursements for receive a utility allowance but will not Expenditures)

PH (1.m.) receive additional money if the utility allowance is greater than the total Tenant Rent Policies: tenant payment. Utility Reimbursements for

HCV (1.n.)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent Policies: The following deductions for Cost- Neutral Elimination of nonelderly and nondisabled families Effectiveness (Decreased Deductions for PH will be eliminated: the $480 allowance expenditures and (1.r.) for each minor dependent in a Increased

Tenant Rent Policies: household and the childcare allowance expenditures) for out-of-pocket expenses for the care Elimination of of minors younger than 13. Deductions for HCV (1.s.)

Tenant Rent Policies: The PHA will exclude all full-time Cost- Neutral (no cost

Alternative Income student-earned income for other Effectiveness implications) Inclusions/Exclusions household members aged 18 to 24. Self-Sufficiency for PH (1.v.) This income exclusion will apply to full-time students other than the head of Tenant Rent Policies: household, co-head of household, and Alternative Income spouse. For other household members Inclusions/Exclusions between the ages of 18 to 21 who are for HCV (1.w.) not full-time students, Housing Alliance

and Community Partnership will exclude income in the same fashion.

Payment Standards: The payment standards will be Housing Choice Negative Fair Market Rents increased from 110 to 120 percent of (Increased (FMR) for HCV (2.b.) FMR. The change will take effect at a Expenditures)

household’s first annual review.

Rent The PHA will conduct inspections and Cost- Positive Reasonableness: determine rent reasonableness for Effectiveness (Decreased Third-Party PHA-owned units rather than hire a expenditures) Requirement for third-party to do this work.

HCV (2.d.)

Reexaminations: The reexamination schedule will be Cost- Positive Alternative adjusted to be triennial for elderly and Effectiveness (Decreased Reexamination disabled households. expenditures) Self-Sufficiency Schedule for

Households for PH (3.a.)

Reexaminations: Alternative

Reexamination Schedule for Households for HCV

(3.b.)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Landlord Incentives: The PHA will establish a vacancy loss Housing Choice Negative Vacancy Loss for and damage mitigation fund. To qualify (Increased HCV (4.a.) for the vacancy loss, landlords must expenditures) have been leasing to an HCV recipient

prior to the vacancy. The PHA will provide up to 1 month of rent as a vacancy loss payment if the landlord leases to an HCV participant off the PHA waiting list.

Landlord Incentives: The PHA will establish a vacancy loss Housing Choice Negative Damage Claims for and damage mitigation fund. Landlords (Increased HCV (4.b.) who wish to apply for assistance from expenditures) the damage mitigation fund must have

experienced damages to a unit exceeding the security deposit amount.

Landlord Incentives: The PHA will offer a lease-up incentive Housing Choice Negative Other Landlord of $300. To qualify for this incentive, (Increased

Incentives for HCV the landlord or property owner must expenditures) (4.c.) rent a new unit to an individual or family on the PHA waiting list. The amount of the incentive will be reduced

by $75 each time a reinspection is required due to any life-threatening failures or 10 or more nonlife-threatening failures.

Housing Quality The PHA will conduct inspections and Cost- Positive

Standards: Third- determine rent reasonableness for Effectiveness (Decreased Party Requirement PHA-owned units rather than contract expenditures) for HCV (5.c.) this work to a third party.

Housing Quality Units with good inspection histories of Cost- Positive

Standards: at least two consecutive passing Effectiveness (Decreased Alternative inspections may be eligible for a expenditures) Housing Choice Inspection Schedule biennial inspection schedule at the for HCV (5.d.) discretion of the PHA. To be eligible

for biennial inspection, the previous inspection must have had zero life-threatening failures and less than five nonlife-threatening failures later corrected.

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

PBV Program The competitive process for the Cost- Positive Flexibilities: placement of PBV will be eliminated. Effectiveness (Increased Elimination of PBV Revenue) Selection Process for

PHA Properties without Improvement, Development, or

Replacement of Public Housing Site (9.c)

PBV Program The PHA will alter the selection Housing Choice Positive Flexibilities: process to increase the opportunity to (Increased

Alternative PBV develop PBVs in the future. Revenue) Selection Process (9.d.)

MTW Self- The PHA will create a skills and Self-Sufficiency Negative Sufficiency Program: development center as part of an MTW (Increased Policies for self-sufficiency program. Financial Expenditures) Addressing incentives will be attached to goals for Increases in Family the families participating in the MTW Income for PH and self-sufficiency program. The PHA will

HCV (11.b.) follow the guidelines of the Family Self Sufficiency program for creating an escrow. Other incentives will include assisting with the cost of tuition or

items that may be required for on-the-job training or permanent employment.

HCV = Housing Choice Voucher. MTW = Moving to Work. PBV = Project-Based Voucher. PH = public housing. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in February 2023 Exhibit B-9(a). Background Information for Ruston Housing Authority (LA-054)

Location Ruston, Louisiana ACC Amendment March 2021 Approval

Programs and HCV: 0 units MTW Supplement FY2021: September Inventory Approvals 2021 Public Housing: 299

units FY2022: July 2022

Special Purpose No Total MTW Waivers 9 Vouchers Approved RAD Conversion No Use of PBVs No

ACC = Annual Contributions Contract. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. Sources: MTW Supplements; interview with PHA in February 2023; HUD communications

Exhibit B-9(b). Approved MTW Waivers as of March 31, 2023, for Ruston Housing Authority (LA-054)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent A stepped rent will be implemented in Cost- Positive Policies: Stepped tandem with a minimum rent (Waiver Effectiveness (Increased Rent for PH (1.c.) 1.e.) for nonelderly and nondisabled revenue and Self-Sufficiency households through the decreased STEPPINGSTONE program. Every 2 expenditures) years, at recertification, households will be subject to a set rent increase (as a

percentage of gross income) in preparation for program graduation.a The PHA will make all necessary referrals to partner organizations to support households preparing for the termination of their assistance.

Tenant Rent The minimum rent for nonelderly and Cost- Positive Policies: Minimum nondisabled households in the Effectiveness (Increased Rent for PH (1.e.) STEPPINGSTONE program will revenue and Self-Sufficiency increase from $50 to $130 per month. decreased expenditures)

Tenant Rent Through the STEPPINGSTONE Cost- Positive Policies: program for nonelderly and nondisabled Effectiveness (Increased Elimination of households, the PHA will eliminate the revenue and Self-Sufficiency Deductions for PH dependent allowance deduction and decreased (1.r.) deductions for unreimbursed childcare expenditures) costs. The PHA is also eliminating the standard rent based on adjusted

income. TTP will be calculated based on gross income.

Reexaminations: Households eligible for the Cost- Positive Alternative STEPPINGSTONE program (nonelderly Effectiveness (Increased Reexamination and nondisabled) will move to a biennial revenue and Self-Sufficiency Schedule for reexamination schedule. Households decreased Households (3.a.) not eligible for the STEPPINGSTONE expenditures) program (elderly or disabled, or both) will move to a triennial reexamination

schedule.

Reexaminations: The PHA will increase the threshold for Cost- Positive Self-Certification of the self-certification of assets from Effectiveness (Decreased Assets (3.c.) $5,000 to $25,000. expenditures)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Term-Limited All households of the Cost- Positive Assistance: Term-STEPPINGSTONE program (nonelderly Effectiveness (Increased Limited Assistance and nondisabled) will be subject to a revenue and Self-Sufficiency (7.a.) time-limited housing term of 5 years. decreased

Households requiring additional time to expenditures) exit the public housing program may apply for a 1-year extension. The 1-year extension can be applied for and

granted a maximum of two times. The absolute household term-limit is 7 years. Households that reach 7 years of tenancy with the PHA, regardless of

consecutiveness, will be unable to reapply for the public housing program. Supportive services will be offered to households as they transition off the program.

MTW Self- The STEPPINGSTONE program will be Cost- Positive Sufficiency mandatory for all PHA residents aged Effectiveness (Increased Program—- between 18 and 62 who are not legally revenue and Self-Sufficiency Alternative Family designated as disabled. Disabled decreased

Selection residents are not required to participate expenditures) Procedures (11.a.) but can voluntarily participate in all program offerings.

MTW Self- Income increases, for purposes of Cost- Positive Sufficiency increasing the tenant-paid portion of Effectiveness (Increased

Program: Policies rent, will be disregarded until the revenue and Self-Sufficiency for Addressing household’s next scheduled decreased Increases in Family recertification. Upon recertification, rent expenditures) Income (11.b.) increases will be phased in over 2

years.

Work Requirement: The PHA will implement a mandatory Cost- Positive Work Requirement work requirement for all nonelderly and Effectiveness (Increased (12.a.) nondisabled individuals aged between revenue and Self-Sufficiency 18 and 62. These individuals must work decreased a minimum of 15 hours per week or the expenditures) equivalent number of hours in 1 year (780 hours). The requirement applies to

all eligible households with a maximum requirement of 30 hours per week per household. Individuals working less than 15 hours a week must complete at least 8 hours of community service per month.

MTW = Moving to Work. PH = public housing. PHA = public housing agency. TTP = total tenant payment. a In the first year, tenant rent would be set at 20 percent of gross income. In the third year, rent would be set at 20 percent of gross income plus an inflation adjustment of 4 percent of Fair Market Rent (FMR). In the fifth year, rent would increase to 25 percent of gross income plus 4 percent of FMR. In the seventh and final year, rent would rise to 32 percent of gross income plus 4 percent of FMR. The PHA is also increasing the minimum rent to $130, and the household pays the higher of this stepped rent or the minimum rent. Sources: MTW Supplement; interview with PHA in February 2023

Exhibit B-10(a). Background Information for Rockville Housing Enterprises (MD-007)

Location Rockville, Maryland ACC Amendment March 2021 Approval

Programs and HCV: 414 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 108 FY2022: July 2022 units

Special Purpose FYI, Mainstream, Total MTW Waivers 19 Vouchers Moderate Rehabilitation, Approved VASH RAD Conversion No Use of PBVs Yes

ACC = Annual Contributions Contract. FY = fiscal year. FYI = Foster Youth to Independence. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. VASH = Veterans Affairs Supportive Housing. Sources: MTW Supplements; interview with PHA in February 2023; HUD communications

Exhibit B-10(b). Approved MTW Waivers as of March 31, 2023, for Rockville Housing Enterprises (MD-007)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent Policies: The total tenant payment will increase Cost- Positive Stepped Rent for PH based on household income increases Effectiveness (Increased (1.c.) or 5 percent each year, whichever is revenue and Self-Sufficiency greater, for families on annual decreased Tenant Rent Policies: recertification schedules and 10 expenditures) Stepped Rent for percent every 3 years for families with HCV (1.d.) triennial recertification schedules.

Tenant Rent Policies: The minimum rent will increase from Cost- Positive Minimum Rent for $50 to $130 for all nonelderly, Effectiveness (Increased

PH (1.e.) nondisabled households. revenue and Self-Sufficiency decreased Tenant Rent Policies: expenditures) Minimum Rent for PH (1.f.)

Tenant Rent Policies: The maximum family rent share will Self-Sufficiency Neutral (no cost

Initial Rent Burden increase from 40 percent to 50 percent implications) Housing choice for HCV (1.o.) of adjusted monthly income.

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent Policies: The PHA will eliminate the Earned Cost- Neutral (no cost Alternative Income Income Disregard and add an Effectiveness implications) Inclusions/Exclusions allowance for money spent directly on Self-Sufficiency for PH (1.v.) educational expenses. The PHA will

Tenant Rent Policies: exclude income for full-time student household members (regardless of Alternative Income household head status). The income Inclusions/Exclusions exclusion will equal the amount the for PH (1.w.) student paid for educational costs (for example, books, tuition, fees, and other expenses).

Payment Standards The PHA will remove the requirement Cost- Positive and Rent to have a third-party perform rent Effectiveness (Decreased

Reasonableness: reasonableness determinations on expenditures) Third-Party project-based voucher (PBV) units Requirement for owned, managed, or controlled by the HCV (2.d.) PHA.

Reexaminations: Reexaminations will be reduced from Cost- Positive

Alternative an annual to a triennial schedule for all Effectiveness (Decreased Reexamination “work-able families” (nonelderly and expenditures) Self-Sufficiency Schedule for PH nondisabled) and all “nonwork-able Households (3.a.) families” (fixed-income families).

Reexaminations: Annual recertifications will remain for families claiming zero income and Alternative families making less than the minimum Reexamination rent income level. Schedule for PH

Households (3.b.)

Reexaminations: The PHA will increase the threshold for Cost- Positive Self-Certification of the self-certification of assets from Effectiveness (Decreased Assets for PH (3.c.) $5,000 to $25,000. expenditures)

Reexaminations:

Self-Certification of Assets for HCV (3.d.)

Housing Quality The PHA will remove the requirement Cost- Positive Standards (HQS): to have a third-party perform HQS Effectiveness (Decreased

Third-Party inspections on PBV units owned, expenditures) Requirement for managed, or controlled by the PHA. HCV (5.c.)

PBV Program The cap on the number of vouchers Cost- Positive Flexibilities: Increase that can be project-based will increase Effectiveness (Increased

PBV Program Cap from 20 to 50 percent. revenue) Housing Choice (9.a.)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

PBV Program The cap on the percentage of PBVs Cost- Positive Flexibilities: Increase that can be project-based in a building Effectiveness (Increased PBV Project Cap or project will increase from 25 percent revenue) Housing Choice (9.b.) to 100 percent.

PBV Program The PHA will eliminate the selection Cost- Positive

Flexibilities: process in the award of PBVs to Effectiveness (Decreased Elimination of PBV properties owned by the PHA, not expenditures) Housing Choice Selection Process for public housing, without engaging in an PHA-owned Projects initiative to improve, develop, or

Without replace a public housing property on Improvement, site. Development, or Replacement of PH

Site (9.c.)

PBV Program The length of a project-based contract Cost- Positive Flexibilities: Increase term will increase to 50 years, Effectiveness (Increased PBV HAP Contract including extensions subject to revenue) Housing Choice Length (9.f.) appropriations and the end of the

MTW Authorization.

PBV Program The requirement to provide a tenant- Cost- Positive Flexibilities: Limit based voucher at 12 months after Effectiveness (Increased Portability for PBV program entry when requested by a revenue and Housing Choice Units (9.h.) PBV household will be delayed to 24 decreased

months after program entry. expenditures)

Local, Nontraditional The PHA will use block grant funding Cost- Neutral (no cost Activities: Housing to acquire, renovate, and/or build Effectiveness implications) Development affordable, but not public housing, Housing Choice Programs (17.c.) units for low-income families. Activities

would be inclusive of, but not limited to, construction financing, gap financing, funding of reserves, and

guarantees for nonpublic housing authority development of affordable housing. Development or investment in other affordable housing will include a

variety of funding sources, including, but not limited to, PBVs, Low Income Housing Tax Credits (LIHTC), federally insured loans, and state and local

funding. Ownership structures are expected to vary depending on the deal structure.

HAP = Housing Assistance Payment. HCV = Housing Choice Voucher. MTW = Moving to Work. PH = public housing. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in February 2023 Exhibit B-11(a). Background Information for the Housing Redevelopment Authority of Hibbing (MN-004)

Location Hibbing, Minnesota ACC Amendment April 2021 Approval

Programs and HCV: 0 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 252 FY2022: December units 2021

Special Purpose No Total MTW Waivers 1 Vouchers Approved RAD Conversion No Use of PBVs No

ACC = Annual Contributions Contract. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. Sources: MTW Supplements; interview with PHA in February 2023; HUD communications

Exhibit B-11(b). Approved MTW Waivers as of March 31, 2023, for the Housing and Redevelopment Authority of Hibbing (MN-004)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

MTW Self- The self-sufficiency program, Self-Sufficiency Neutral (no cost Sufficiency EMPOWER, will be mandatory for all implications) Housing Choice Program: PHA residents aged between 18 and 62 Alternative Family who are not legally designated as Selection disabled. New residents who meet these Procedures (11.a.) criteria will sign a one-page lease

addendum agreeing to the terms of the program at move-in after January 1, 2022. Existing residents as of January 1, 2022, will also sign the same one-page

lease addendum during their annual recertification. If an elderly or disabled resident still wishes to voluntarily enter

the program, they are free at any time to meet with the MTW coordinator to discuss entering the program under a unique agreement.

MTW = Moving to Work. PHA = public housing agency.

Sources: MTW Supplement; interview with PHA in February 2023

Exhibit B-12(a). Background Information for Kandiyohi County Housing and Redevelopment Authority (MN-168)

Location Wilmar, Minnesota ACC Amendment September 2021 Approval

Programs and HCV: 377 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 174 FY2022: August 2022 units

Special Purpose No Total MTW Waivers 4 Vouchers Approved RAD Conversion No Use of PBVs Yes

ACC = Annual Contributions Contract; FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. Sources: MTW Supplements; interview with PHA in March 2023; HUD communications

Exhibit B-12(b). Approved MTW Waivers as of March 31, 2023, for Kandiyohi County Housing and Redevelopment Authority (MN-168)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Payment Payment standards will be increased Housing Choice Negative Standards and from 110 to 120 percent of FMR. (Increased

Rent expenditures) Reasonableness: Payment Standards—Fair

Market Rents for HCV (2.b.)

Reexaminations: Reexamination schedules for all HCV Cost- Neutral (no cost Alternative households will be adjusted from an Effectiveness implications) Reexamination annual to a biennial schedule.

Schedule for PH Households may request interim Households (3.a.) recertifications as needed.

Reexaminations:

Alternative Reexamination Schedule for HCV Households (3.b.)

FSS Program with The PHA will end its required HCV FSS Cost- Neutral (no cost

MTW Flexibility: program. Effectiveness implications) Waive Operating a Required FSS Program for HCV

(10.a.)

FMR = Fair Market Rent. FSS = Family Self-Sufficiency. HCV = Housing Choice Voucher. MTW = Moving to Work. PH = public housing. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in March 2023 Exhibit B-13(a). Background Information for McLeod County Housing and Redevelopment Authority (MN-203)

Location Wilmar, Minnesota ACC Amendment September 2021 Approval

Programs and HCV: 121 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 0 units FY2022: August 2022

Special Purpose No Total MTW Waivers 3 Vouchers Approved RAD Conversion No Use of PBVs No

ACC = Annual Contributions Contract. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. Sources: MTW Supplements; interview with PHA in March 2023; HUD communications

Exhibit B-13(b). Approved MTW Waivers as of March 31, 2023, for McLeod County Housing and Redevelopment Authority (MN-203)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Payment Payment standards will increase from Housing Choice Negative Standards and 110 to 120 percent of FMR. (Increased

Rent expenditures) Reasonableness: Payment Standards—Fair

Market Rents for HCV (2.b.)

Reexaminations: Reexamination schedules for all HCV Cost- Neutral (no cost Alternative households will be adjusted from an Effectiveness implications) Reexamination annual to a biennial schedule.

Schedule for HCV Households may request interim Households (3.b.) recertifications as needed.

FSS Program with The PHA will end its required HCV FSS Cost- Neutral (no cost MTW Flexibility: program. Effectiveness implications)

Waive Operating a Required FSS Program for HCV (10.a.)

FMR = Fair Market Rent. FSS = Family Self-Sufficiency. HCV = Housing Choice Voucher. MTW = Moving to Work. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in March 2023 Exhibit B-14(a). Background Information for Washington County Community Development Agency (MN-212)

Location Woodbury, Minnesota ACC Amendment March 2021 Approval

Programs and HCV: 115 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 105 FY2022: December units 2022

Special Purpose Mainstream, VASH Total MTW Waivers 8 Vouchers Approved RAD Conversion No Use of PBVs No

ACC = Annual Contributions Contract. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. VASH = Veterans Affairs Supportive Housing. Sources: MTW Supplements; interview with PHA in February 2023; HUD communications

Exhibit B-14(b). Approved MTW Waivers as of March 31, 2023, for Washington County Community Development Agency (MN-212)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent Policies: The maximum family rent share at Housing Choice Neutral (no cost Initial Rent Burden initial lease up will increase from 40 to implications) for HCV (1.o.) 50 percent of adjusted monthly

income.

Tenant Rent Policies: Income from assets less than $50,000 Cost- Negative Alternative Income will be excluded from the tenant rent Effectiveness (Decreased Inclusions/Exclusions calculation. revenue and for PH (1.v.) increased

Tenant Rent Policies: expenditures) Alternative Income Inclusions/Exclusions for HCV (1.w.)

Payment Standards The PHA will perform rent reasonable Cost- Positive

and Rent determinations on all HCV units in Effectiveness (Decreased Reasonableness: buildings owned by the PHA rather expenditures) Third-Party than hire a third party. Requirement for

HCV (2.d.)

Reexaminations: Households will be allowed to self- Cost- Neutral (no cost Self-Certification of certify up to $50,000 in assets. Effectiveness implications) Assets for PH (3.c.)

Reexaminations:

Self-Certification of Assets for PH (3.d.)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Housing Quality The PHA will conduct HQS inspections Cost- Neutral (no cost Standards (HQS): on units the housing authority owns Effectiveness implications) Third-Party rather than hire a third party. Requirement for

HCV (5.c.)

Agency-Specific For HQS inspections, the PHA will Cost- Positive Waiver allow landlords to self-certify that a unit Effectiveness (Decreased has no life-threatening deficiencies on expenditures) the lease start date for move-ins. A

physical inspection must be scheduled within 60 days of move-in.

HCV = Housing Choice Voucher. MTW = Moving to Work. PH = public housing. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in February 2023

Exhibit B-15(a). Background Information for Ripley County Public Housing Agency (MO-212)

Location Poplar Bluff, Missouri ACC Amendment June 2021 Approval

Programs and HCV: 410 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 0 units FY2022: February 2022

Special Purpose Nonelderly Disabled Total MTW Waivers 6 Vouchers Approved

RAD Conversion Yes (PBRA) Use of PBVs No

ACC = Annual Contributions Contract. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBRA = Project-Based Rental Assistance. PBV = project-based voucher. RAD = Rental Assistance Demonstration. Sources: MTW Supplements; interview with PHA in February 2023; HUD communications

Exhibit B-15(b). Approved MTW Waivers as of March 31, 2023, for Ripley County Public Housing Agency (MO-212)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent The minimum rent will increase from $50 Self-Sufficiency Neutral (no cost Policies: Minimum to 30 percent of monthly income (based implications) Rent for HCV (1.f.) on annual reported income) for nonelderly, nondisabled households with

an annual adjusted income of $2,000 or higher a

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Payment The payment standard for an efficiency Housing Choice Negative Standards and and one-bedroom unit will increase to (Increased Rent 110 percent of Fair Market Rent (FMR). expenditures) Reasonableness: Two-bedroom and larger units will

Payment continue to have a payment standard at Standards—Fair 100 percent of FMR b Market Rents for HCV (2.b.)

Payment The PHA staff will conduct annual rent Housing Choice Neutral (no cost

Standards and surveys to assist in rent reasonableness implications) Rent determinations and ensure that the rent Reasonableness: charged does not exceed rents currently Process for HCV charged by the owner for comparable,

(2.c.) unassisted units. Rent reasonableness is determined by directly contacting landlords with open units and locating the rent amount for those units

independent of an HCV tenant occupant.

Short-Term The PHA will set aside 10 vouchers for Self-Sufficiency Neutral (no cost Assistance for people currently experiencing implications) HCV (6.b.) homelessness to be used for emergency, short-term assistance,

including any utility and rental deposits if such funds are not available from other sources. The term of this assistance shall not exceed 12 months. At that

point, the tenant must meet a self-sufficiency standard that will enable the tenant to move to the regular voucher program for the remaining time of the

established term of assistance or graduate entirely from the program. Nonelderly and nondisabled short-term

assistance tenants are required to participate in supportive services offered by partners of the PHA based on the tenant’s current needs.

MTW Self- All nonelderly, nondisabled individuals Self-Sufficiency Negative

Sufficiency will be required to participate in the (Increased Program: Family Self-Sufficiency (FSS) program. expenditures) Alternative Family Participants will be given a preference Selection ahead of elderly and disabled persons

Procedures for on the FSS waiting list because the goal HCV (11.a.) of the FSS program is to get able-bodied individuals the tools they need to become self-sufficient.

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Work Requirement Nonelderly and nondisabled persons will Self-Sufficiency Positive for HCV (12.b.) be required to adhere to a work (decreased requirement policy. Each eligible expenditures) individual living in the household will be

required to obtain a minimum of 15 hours of work or school per week, documented by submitting payroll check stubs or semester grade sheets from an

educational institution during the quarterly review process with FSS. Each individual will have access to support services from area employment support

agencies. Failure to comply with the work requirement will result in the termination of HCV.

HCV = Housing Choice Voucher. MTW = Moving to Work. PHA = public housing agency. a This waiver was approved as part of the MTW Supplement but is not a policy change. A household with $2,000 or less annual adjusted income would pay the minimum rent of $50, and a household above $2,000 would pay 30 percent of income (as their total tenant payment is above $50). This waiver was approved as part of the MTW Supplement, but in practice, PHAs are allowed to set the payment b standard between 90 and 110 percent of FMR under regular program regulations. Sources: MTW Supplement; interview with PHA in February 2023 Exhibit B-16(a). Background Information for Robeson County Housing Authority (NC-084)

Location Lumberton, North ACC Amendment April 2021 Carolina Approval

Programs and HCV: 0 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 290 FY2022: June 2022 units

Special Purpose No Total MTW Waivers 5 Vouchers Approved RAD Conversion No Use of PBVs No

ACC = Annual Contributions Contract. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. Sources: MTW Supplements; interview with PHA in February 2023; HUD communications

Exhibit B-16(b). Approved MTW Waivers as of March 31, 2023, for Robeson County Housing Authority (NC-084)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent The PHA will implement a stepped rent Cost- Not specified Policies: Stepped model that will increase a family’s rent Effectiveness Rent for PH (1.c.) payment on a fixed schedule in both Self-Sufficiency frequency and amount. Each household

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

will start out paying rent equal to 30 percent of their total annual gross income in the past year or a minimum rent of $50 (whichever is greater). The

PHA will establish an annual stepped rent increase by unit size. After Year 1, each household’s rent will increase by an amount unrelated to each household’s

income. The annual stepped rent increase will be 4 percent of the Fair Market Rent. Elderly and disabled families are excluded from the stepped rent policy.

Reexaminations: The frequency of tenant reexaminations Cost- Not specified Alternative will be reduced to triennially for all Effectiveness Reexamination households. Households may request Self-Sufficiency Schedule for one interim adjustment per year if the

Households for household’s gross income has PH (3.a.) decreased by 10 percent or more.

MTW Self- The PHA will develop an MTW basic skill Self-Sufficiency Neutral (no cost Sufficiency set program called BRIDGE. The implications) Program: program will include skills assessment

Alternative Family and job readiness training; health Selection assessment and services referrals; Procedures for PH identification of transportation and (11.a.) childcare needs; basic financial literacy

and credit education; and ready-to-rent training. Participation in the MTW self-sufficiency program will be mandatory for any nonworking and nonelderly,

nondisabled household member. During participation in the MTW program, a household’s income increases will not be

used to change eligibility status for participation in the MTW self-sufficiency program or ability to receive public housing assistance.

Acquisition without The PHA will develop a nonprofit affiliate Housing Choice Neutral (no cost

Prior HUD to enable it to act more like a private implications) Approval for PH housing developer to address local (15) needs, provide flexibility to acquire property on the private market, and

attract more funding through its nonprofit (501(c)(3)) status.

Local, The PHA will use MTW funding to Housing Choice Neutral Nontraditional acquire, renovate and/or build affordable, (Increased Activities: Housing but not public housing, units for low-revenue and

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Development income families. The PHA will use capital increased Programs (17.c.) project funds for predevelopment costs expenditures) associated with developing non-PHA affordable housing.

MTW = Moving to Work. PH = public housing. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in February 2023 Exhibit B-17(a). Background Information for South Sioux City Housing Agency (NE-175)

Location South Sioux City, ACC Amendment April 2021 Nebraska Approval

Programs and HCV: 294 units MTW Supplement FY2021: January 2022 Inventory Approvals Public Housing: 0 units FY2022: June 2022

Special Purpose Enhanced vouchers Total MTW Waivers 5 Vouchers Approved RAD Conversion No Use of PBVs No

ACC = Annual Contributions Contract. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. Sources: MTW Supplements; interview with PHA in February 2023; HUD communications

Exhibit B-17(b). Approved MTW Waivers as of March 31, 2023, for South Sioux City Housing Agency (NE-175)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent The PHA will adopt a standard utility Cost- Positive Policies: allowance based on the number of Effectiveness (Decreased

Alternative Utility bedrooms for HCV households. expenditures) Self-Sufficiency Allowance for HCV (1.j.)

Tenant Rent Utility reimbursements will be eliminated Cost- Positive Policies: Utility when the utility allowance exceeds the Effectiveness (Increased

Reimbursements total tenant payment. revenue and for HCV (1.n.) decreased expenditures)

Payment Payment standards for one-, two-, three-, Housing Choice Negative Standards and and four-bedroom units will increase (Decreased

Rent from 110 percent to 120 percent of the revenue) Reasonableness: Fair Market Rent. Payment Standards- Fair

Market Rents for HCV (2.b.)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Reexaminations: The frequency of reexaminations will Cost- Positive Alternative decrease from annually to biennially for Effectiveness (Decreased Reexamination elderly and disabled households. Elderly expenditures) Schedule for and disabled households are limited to

Households for one interim per year at the request of the HCV (3.b.) household. If the interim is for a decrease in income, only income decreases of 10 percent or more will be

processed. No interim decreases are allowed during the first 6 months after initial occupancy. Required interim recertification for household composition

changes or landlord rent increases will not count against the limit on voluntary interim recertifications.

Work Requirement A work requirement will apply to Cost- Positive for HCV (12.b.) nonelderly and nondisabled individuals. Effectiveness (Increased

Able-bodied household members aged revenue and Self-Sufficiency 18 years and older must work a decreased minimum of 15 hours per week. All able- expenditures) bodied household members aged 18

years and older who are a member of an elderly and/or disabled household must work a minimum of 15 hours per week. Full-time students, live-in aides,

individuals who are the primary caretakers for a child younger than 6 years, and women who are pregnant are exempt from the work requirement.

HCV = Housing Choice Voucher. MTW = Moving to Work. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in February 2023 Exhibit B-18(a). Background Information for Dover Housing Authority (NH-003)

Location Dover, New Hampshire ACC Amendment August 2021 Approval

Programs and HCV: 347 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 274 FY2022: August 2022

units

Special Purpose FYI, Mainstream Total MTW Waivers 8 Vouchers Approved

RAD Conversion Yes (PBV) Use of PBVs Yes

ACC = Annual Contributions Contract. FY = fiscal year. FYI = Foster Youth to Independence. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. Sources: MTW Supplements; interview with PHA in February 2023; HUD communications Exhibit B-18(b). Approved MTW Waivers as of March 31, 2023, for Dover Housing Authority (NH-003)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent Policies: Income from assets will not be counted Cost- Neutral (no cost Alternative Income in the household’s rent calculation. Effectiveness implications)

Inclusions/Exclusions Income changes do not need to be Self-Sufficiency for PH (1.v.) reported until the next scheduled reexamination. Tenant Rent Policies: Alternative Income

Inclusions/Exclusions for HCV (1.W.)

Payment Standards The PHA will collect and maintain data Cost- Neutral (no cost and Rent on market rents in the PHA’s Effectiveness implications) Reasonableness: jurisdiction. Information sources Self-Sufficiency Process for HCV include newspapers, realtors, market (2.c.) surveys, inquiries of owners, and other available sources. The data will be categorized by bedroom size and

market areas. ZIP Codes, census tracts, neighborhoods, and identifiable natural or artificial boundaries may define market areas.

The rent for a unit proposed for HCV assistance will be compared with the rent charged for comparable units in the same market area. The PHA will

develop a range of prices for comparable units by bedroom size within defined market areas. Units proposed for HCV assistance will be

compared with other units within this rent range. Because units may be similar but not exactly like the units proposed for HCV assistance, the PHA

may adjust the range of prices to account for these differences. The adjustment must reflect the local

market. Not all differences in units require adjustments (for example, the presence or absence of a garbage disposal may not affect the rent in some market areas).

Reexaminations: Reexaminations will be reduced from Cost- Neutral (no cost Alternative annually to biennially for all Effectiveness implications) Reexamination households. Households may request Self-Sufficiency Schedule for PH interim recertifications as needed. Households (3.a.) When a change in household

composition occurs, an interim will be

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Reexaminations: conducted and rent recalculated as Alternative needed. Reexamination Schedule for HCV

Households (3.b.)

Reexaminations: The threshold for the self-certification Cost- Neutral (no cost Self-Certification of of assets will be increased to $50,000. Effectiveness implications) Assets for PH (3.c.)

Reexaminations:

Self-Certification of Assets for HCV (3.d.)

FSS Program with The Contract of Participation will be Cost- Neutral (no cost MTW Flexibility: modified to remove the requirements Effectiveness implications) Modify or Eliminate that a head of household must be Self-Sufficiency the Contract of employed, and the household must Participation for HCV have been off TANF assistance for 12 Housing Choice (10.d.) months to graduate from the FSS program. Under the modified contract,

graduation may be granted if the head of household, co-head or another adult in the household is working. The household also does not need to be off TANF for 12 months to graduate.

FSS = Family Self-Sufficiency. HCV = Housing Choice Voucher. MTW = Moving to Work. PH = public housing. PHA = public housing agency. TANF = Temporary Assistance for Needy Families. Sources: MTW Supplement; interview with PHA in February 2023

Exhibit B-19(a). Background Information for Housing Authority of Cheraw (SC-031)

Location Florence, South ACC Amendment March 2021 Carolina Approval

Programs and HCV: 180 units MTW Supplement FY2021: September Inventory Approvals 2021 Public Housing: 230 FY2022: July 2022

Special Purpose No Total MTW Waivers 5 Vouchers Approved RAD Conversion No Use of PBVs No

ACC = Annual Contributions Contract. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. Sources: MTW Supplements; interview with PHA in January 2023; HUD communications Exhibit B-19(b). Approved MTW Waivers as of March 31, 2023, for Housing Authority of Cheraw (SC-031)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent A streamlined utility allowance will Cost- Neutral (no cost Policies: average the cost of the utility allowances Effectiveness implications)

Alternative Utility for zero- to five-bedroom units across Allowance for PH public housing and HCV programs. Utility (1.i.) allowances for bedroom sizes will be the same for both the public housing and Tenant Rent HCV programs. Policies: Alternative Utility Allowance for HCV (1.j.)

Landlord Leasing The PHA will provide up to 10 landlords Housing Choice Positive

Incentives: Other a one-time incentive of $500 to (increased Landlord participate in the HCV program in revenue) Incentives for HCV Chesterfield County. The incentives will Tenant-based be limited to new landlords who have not

Assistance (4.c.) rented through the HCV program.

Local, The PHA will provide a $500 financial Self-Sufficiency Negative Nontraditional incentive to up to 35 working families (Increased Housing Choice Activities: Service that have maintained at least 1 year of expenditures) Provision (17.b.) continued full-time employment (with no

more than a 2-week break in employment). Households may be eligible for one incentive per fiscal year. If more than 35 working families are included, the decision will be made by lottery.

Local, The PHA will partner with a developer Housing Choice Not specified Nontraditional from the Housing Authority of Florence Activities: Housing (managing agency) to explore housing

Development choices, including 99 tax-credit Programs (17.c.) properties and the Rental Assistance Demonstration. HCV = Housing Choice Voucher. MTW = Moving to Work. PH = public housing. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in January 2023

Exhibit B-20(a). Background Information for Maryville Housing Authority (TN-065)

Location Maryville, Tennessee ACC Amendment March 2021 Approval

Programs and HCV: 356 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 400 FY2022: December units 2022

Special Purpose No Total MTW Waivers 6 Vouchers Approved RAD Conversion No Use of PBVs No

ACC = Annual Contributions Contract. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. Sources: MTW Supplements; interview with PHA in March 2023; HUD communications

Exhibit B-20(b). Approved MTW Waivers as of March 31, 2023, for Maryville Housing Authority (TN-065)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Payment Standards Payment standards will increase from Housing Choice Negative and Rent 110 percent to 120 percent of Fair (Increased Reasonableness: Market Rent. expenditures)

Payment Standards- Fair Market Rents for HCV (2.b.)

Reexaminations: The reexamination schedule for Cost- Positive Alternative individuals or entire households on a Effectiveness (Decreased

Reexamination fixed income will change from annual expenditures) Schedule for PH to biennial. Households (3.a.)

Reexaminations:

Alternative Reexamination Schedule for HCV Households (3.b.)

Reexaminations: Households will be allowed to self- Cost- Positive

Self-Certification of certify up to $50,000 in assets. Effectiveness (Decreased Assets for PH (3.c.) expenditures)

Reexaminations: Self-Certification of

Assets for HCV (3.d.)

Landlord Leasing The PHA will offer new landlords Housing Choice Negative Incentives: Other (those who have never rented to an (Decreased

Landlord Incentives HCV recipient) a one-time signing revenue) for HCV Tenant-bonus of up to $500. Payments made based Assistance to a landlord will be equal to no more (4.c.) than 1 month of the contract rent. HCV = Housing Choice Voucher. MTW = Moving to Work. PH = public housing. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in March 2023 Exhibit B-21(a). Background Information for the Housing Authority of Travis County (TX-480)

Location Austin, Texas ACC Amendment April 2021 Approval

Programs and HCV: 617 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 0 units FY2022: September 2022

Special Purpose FUP, Mainstream, NED, Total MTW Waivers 9 Vouchers VASH Approved

RAD Conversion Yes (PBRV) Use of PBVs Yes

ACC = Annual Contributions Contract. FUP = Family Unification Program. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. NED = Nonelderly Disabled. PBV = project-based voucher. RAD = Rental Assistance Demonstration. VASH = Veterans Affairs Supportive Housing. Sources: MTW Supplements; interview with PHA in March 2023; HUD communications

Exhibit B-21(b). Approved MTW Waivers as of March 31, 2023, for the Housing Authority of Travis County (TX-480)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent Minimum rent will increase from $50 to Cost- Positive Policies: Minimum $75. Effectiveness (Decreased Rent for HCV (1.f.) expenditures) Self-Sufficiency

Tenant Rent Total tenant payment will be reduced Cost- Positive

Policies: Tenant from 30 percent to 28 percent of Effectiveness (Decreased Payment as a adjusted income. expenditures) Self-Sufficiency Modified Percentage of

Income for HCV (1.h.)

Tenant Rent A flat utility allowance schedule based on Cost- Positive Policies: unit size (number of bedrooms) will Effectiveness (Decreased Alternative Utility replace the prior schedule based on unit expenditures) Self-Sufficiency Allowance for type, size, and utility source (gas, HCV (1.j.) electricity).

Tenant Rent The maximum initial rent burden will Cost- Positive Policies: Initial increase from 40 percent to 60 percent. Effectiveness (Decreased Rent Burden for The PHA will not approve an initial expenditures) Housing Choice HCV (1.o.) assisted tenancy if the family share exceeds 60 percent of the family’s monthly income.

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent The PHA will eliminate dependent Cost- Positive Policies: allowance and unreimbursed childcare Effectiveness (Decreased Elimination of costs deductions from consideration expenditures) Self-Sufficiency Deduction(s) for when determining total tenant payment.

HCV (1.s.)

Reexaminations: The PHA will reduce the frequency of Cost- Positive Alternative reexaminations from annual to biennial Effectiveness (Decreased Reexamination for all households. The PHA will allow expenditures) Self-Sufficiency Schedule for HCV one interim per year at the request of the

Households (3.b.) household if the household gross income has decreased by 10 percent or more. Changes in household composition will be processed only at biennial

reexamination unless the family reports a household addition that impacts Housing Quality Standards space requirements.

Reexaminations: The PHA will increase the threshold for Cost- Positive Self-Certification the self-certification of assets from Effectiveness (Decreased

of Assets for HCV $5,000 to $25,000. expenditures) Self-Sufficiency (3.d.)

Landlord Leasing The PHA will pay up to 1 month’s rent to Housing Choice Negative Incentives: Other landlords newly participating in HATC’s (increased Landlord HCV tenant-based program. Under this expenditures)

Incentives for HCV initiative, a new landlord is a landlord Tenant-based who has never participated in the PHA’s Assistance (4.c.) tenant-based HCV program.

Housing Quality The PHA will inspect HCV units under Cost- Positive Standards: contract at least once every 3 years. The Effectiveness (Decreased

Alternative PHA will also conduct an inspection at expenditures) Inspection the request of the family or owner. Schedule for HCV (5.d.)

HATC = Housing Authority of Travis County. HCV = housing choice voucher. MTW = Moving to Work. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in March 2023

Exhibit B-22 (a). Background Information for Rosenberg Housing Authority (TX-483)

Location Rosenburg, Texas ACC Amendment March 2021 Approval

Programs and HCV: 453 units MTW Supplement FY2021: September Inventory Approvals 2021 Public Housing: 0 units FY2022: September 2022

Special Purpose FYI, Mainstream Total MTW Waivers 9 Vouchers Approved RAD Conversion No Use of PBVs No

ACC = Annual Contributions Contract. FY = fiscal year. FYI = Foster Youth to Independence. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. Sources: MTW Supplements; interview with PHA in February 2023; HUD communications

Exhibit B-22(b). Approved MTW Waivers as of March 31, 2023, for Rosenberg Housing Authority (TX-483)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent Policies: Minimum rent will increase from $50 to Self-Sufficiency Positive Minimum Rent for $100 over 2 years. During the first year (Decreased HCV (1.f.) of implementation, the minimum rent expenditures)

will increase to $75. In the second year of implementation, the minimum rent will increase to $100.

Tenant Rent Policies: The percentage used to calculate rent Cost- Positive Tenant Payment as will be lowered to 27.5 percent of a Effectiveness (Decreased

a Modified household’s monthly gross income for expenditures) Self-Sufficiency Percentage of all HCV participants and new Income for HCV admissions and eliminate allowances (1.h.) and deductions (childcare).

Tenant Rent Policies: Utility reimbursements will be Cost- Positive

Utility eliminated when the utility allowance Effectiveness (Decreased Reimbursements for exceeds the total tenant payment. expenditures) Self-Sufficiency HCV (1.n.)

Tenant Rent Policies: The maximum initial rent burden will Housing Choice Neutral (no cost Initial Rent Burden increase from 40 percent to 45 percent implications)

for HCV (1.o.) of a household’s monthly adjusted income.

Tenant Rent Policies: The dependent allowance and Cost- Positive Elimination of unreimbursed childcare cost Effectiveness (Decreased

Deduction(s) for HCV deductions will be eliminated when expenditures) Self-Sufficiency (1.s.) calculating rent.

Tenant Rent Policies: The PHA will eliminate requesting Cost- Neutral (no cost Alternative Income asset income when calculating rent. Effectiveness implications) Inclusions/Exclusions

for HCV (1.w.)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Reexaminations: The frequency of reexaminations will Cost- Negative Alternative be reduced to biennially for working Effectiveness (increase Reexamination families (those in which the head of expenditures) Schedule for HCV household, co-head of household,

Households (3.b.) spouse, or another adult is working and making at least $7,250 per year and not a full-time student) and triennially for elderly or disabled

families if 90 percent or more of their income is fixed. Families with zero income or work-able families with no wage income will remain on an annual

reexamination schedule. Interim reexaminations will be conducted once per year if a household has a decrease in income greater than 10 percent after

6 months of initial occupancy (including port-ins), a family composition change that increases income, or the household income increases while paying at or below the minimum rent.

Housing Quality Rental units will qualify for a triennial Cost- Positive Standards: inspection if the family has passed Effectiveness (Decreased Alternative their 1-year and biennial inspections on expenditures) Inspection Schedule the first visit.

for HCV (5.d.)

FSS Program with The PHA will eliminate the FSS Cost- Neutral (no cost MTW Flexibility: HCV program due to the nonparticipation of Effectiveness implications) Waive Operating a the one required family. Required FSS

Program for HCV (10.a.)

FSS = Family Self-Sufficiency. HCV = Housing Choice Voucher. MTW = Moving to Work. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in February 2023 Exhibit B-23(a). Background Information for Bristol Redevelopment Housing Authority (VA-002)

Location Bristol, Virginia ACC Amendment March 2021 Approval

Programs and HCV: 303 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 388 FY2022: March 2022

units

Special Purpose EHV, Mainstream Total MTW Waivers 21 Vouchers Approved

RAD Conversion No Use of PBVs No, but planned.

ACC = Annual Contributions Contract. EHV = Emergency Housing Vouchers. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. Sources: MTW Supplements; interview with PHA in February 2023; HUD communications

Exhibit B-23(b). Approved MTW Waivers as of March 31, 2023, for Bristol Redevelopment and Housing Authority (VA-002)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent Utility reimbursement payments will be Cost- Positive Policies: Utility eliminated when the utility allowance Effectiveness (increased Reimbursements exceeds the total tenant payment. revenue and Self-Sufficiency for HCV (1.n.) decreased

expenditures)

Tenant Rent Expense deductions for unreimbursed Cost- Neutral (no cost Policies: childcare expenses and medical Effectiveness implications) Elimination of expenses will be eliminated when Deductions for PH determining rent.

(1.r.)

Tenant Rent Policies: Elimination of

Deductions for HCV (1.s.)

Tenant Rent The PHA will implement a standard Cost- Neutral (no cost Policies: Standard medical deduction of $1,500 for elderly Effectiveness implications) Deductions for PH and disabled families and a standard

(1.t.) childcare deduction of $1,030 (per child) for working families. Tenant Rent Policies: Standard Deductions for

HCV (1.u.)

Payment Payment standards will increase to 120 Housing Choice Negative Standards and percent for all bedroom sizes. (increased Rent expenditures)

Reasonableness: Payment Standards- Fair Market Rents for

HCV (2.b.)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Reexaminations: The reexamination schedule will shift to Cost- Positive Alternative triennial for all assisted families. The Effectiveness (decreased Reexamination number of interim reexaminations will be expenditures) Self-Sufficiency Schedule for PH limited to one per year if the household’s

Households (3.a.) gross income has decreased 10 percent Housing Choice or more. For zero-income households, Reexaminations: an interim reexamination will occur every Alternative 3 months. Changes in household Reexamination composition will also result in an interim Schedule for HCV reexamination. Households (3.b.)

Reexaminations: The PHA will increase the threshold for Cost- Positive Self-Certification the self-certification of assets from Effectiveness (decreased of Assets for PH $5,000 to $25,000. expenditures) Self-Sufficiency (3.c.)

Reexaminations: Self-Certification of Assets for HCV

(3.d.)

Landlord Landlords will receive a vacancy loss Housing Choice Neutral Incentives: payment of up to 1 month of contract (Increased Vacancy Loss for rent for the prior lease on execution of a revenue and HCV (4.a.) new Housing Assistance Payment (HAP) increased

contract. expenditures)

Landlord The PHA will offer the following Housing Choice Neutral Incentives: Other incentives to landlords: a referring (Increased Landlord landlord bonus of $500 for a referral of revenue and Incentives for HCV any new landlord (no history with the increased

(4.c.) HCV program for the past 5 years) that expenditures) results in a new HAP contract, a $25 property maintenance bonus, and an initial $50 Housing Quality Standards

(HQS) bonus for passing inspection on the first visit. The PHA will also support a $500 first-time lease-up bonus, a $200 retention bonus, and $30 application fees. a

Housing Quality During an HCV unit’s next scheduled Cost- Positive Standards: biennial inspection (currently allowed for Effectiveness (decreased Alternative the PHA), if the unit passes at the first expenditures)

Inspection inspection (no reinspection needed), the Schedule for HCV unit will change to a triennial inspection. (5.d.) If the unit does not pass the first HQS inspection, it will be placed on a special

inspection status.

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

PBV Program The maximum percent of authorized Cost- Positive Flexibilities: HCV units authorized for project-basing Effectiveness (increased Increase PBV will increase to 50 percent. revenue) Housing Choice Program Cap

(9.a.)

PBV Program The PBV cap within a housing project Cost- Positive Flexibilities: will increase to 100 percent. Effectiveness (increased Increase PBV revenue) Housing Choice Project Cap (9.b.)

PBV Program The PHA will use PBVs to assist in Cost- Positive

Flexibilities: renovating BRHA owned properties. Effectiveness (decreased Elimination of PBV expenditures) Housing Choice Selection Process for PHA-owned

Projects Without Improvement, Development, or Replacement of

Public Housing Site (9.c.)

PBV Program The PHA will develop a local process to Cost- Neutral (no cost Flexibilities: determine the initial and redetermined Effectiveness implications) Increase PBV rent to an owner. Housing Choice Rent to Owner (9.g.)

PBV Program Portability will be limited by delaying Cost- Positive Flexibilities: Limit when a household can request to move Effectiveness (decreased Portability for PBV from a PBV to a tenant-based voucher. expenditures)

Units (9.h.) Households must now have been in the PBV unit for 2 years instead of 1 before requesting a tenant-based voucher.

Family Self- Households participating in the self- Self-Sufficiency Negative

Sufficiency sufficiency program will be allowed to (increased Program with request to have annual reexaminations expenditures) MTW Flexibility: conducted if they experience income Policies for increases of 10 percent or more, which

Addressing will allow income increases to be Increases in recognized for increasing rent or Family Income for changing the amount of funds moved to PH (10.e.) escrow and savings through the

program.

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Use of PH as an The PHA will extend the period for which Self-Sufficiency Neutral (no cost Incentive for a household can be over-income while implications) Economic remaining in a subsidized public housing Progress (13) unit to 2 years with their subsidy.

Acquisition without The PHA will use this wavier to expedite Housing Choice Neutral (no cost

Prior HUD the ability to acquire property to implications) Approval for PH redevelop existing public housing units (15) without going through the lengthy HUD process.

HCV = Housing Choice Voucher. MTW = Moving to Work. PBV = Project-Based Voucher. PH = public housing. PHA = public housing agency. a These three incentives are listed under the landlord incentives vacancy loss for HCV waiver (4.a), but the evaluation team is reporting on them under other landlord incentives. Sources: MTW Supplement; interview with PHA in February 2023

Exhibit B-24(a). Background Information for Harrisonburg Redevelopment Housing Authority (VA-014)

Location Harrisonburg, Virginia ACC Amendment March 2021 Approval

Programs and HCV: 883 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 0 units FY2022: November 2022

Special Purpose FUP, Mainstream, NED, Total MTW Waivers 20 Vouchers VASH Approved RAD Conversion No Use of PBVs Yes

ACC = Annual Contributions Contract. FUP = Family Unification Program. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. NED = Nonelderly Disabled. PBV = project-based voucher. RAD = Rental Assistance Demonstration. VASH = Veterans Affairs Supportive Housing. Sources: MTW Supplements; interview with PHA in February 2023; HUD communications

Exhibit B-24(b). Approved MTW Waivers as of March 31, 2023, for Harrisonburg Redevelopment HA (VA-014)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent Policies: The minimum rent will increase from Cost- Positive Minimum Rent for $50 to $100 for all nonelderly, Effectiveness (increased HCV (1.f.) nondisabled households. revenue)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent Policies: The maximum total tenant payment Cost- Neutral (no cost Tenant Payment as (TTP) will increase to 35 percent of Effectiveness implications) a Modified adjusted income for all nonelderly Percentage of nondisabled households.

Income for HCV (1.h.)

Tenant Rent Policies: The PHA will create one utility Cost- Positive Alternative Utility allowance for all unit types that varies Effectiveness (decreased Allowance for HCV by bedroom size and whether unit rent expenditures) Housing Choice (1.j.) includes utilities. Project-based voucher (PBV) units may have a separate utility allowance.

Tenant Rent Policies: Utility reimbursements less than $20 Cost- Positive Utility per month will be eliminated. Effectiveness (decreased

Reimbursements for expenditures) HCV (1.n.)

Tenant Rent Policies: Deductions for unreimbursed childcare Cost- Neutral (no cost Elimination of expenses will be eliminated when Effectiveness implications) Deductions for HCV calculating rent for all nonelderly,

(1.s.) nondisabled households.

Tenant Rent Policies: The PHA will eliminate the Earned Cost- Neutral (no cost Alternative Income Income Disallowance and exclude all Effectiveness implications) Inclusions/Exclusions types of school grants and school Self-Sufficiency for HCV (1.w.) funding from income for students of

any age. For nonstudent household members, the rent calculation will not include wage income from dependents aged 20 and younger. The rent

calculation will count the wage income of household members 21 and older. This change does not apply to elderly or disabled households.

Payment Standards: Payment standards will increase to Housing Choice Negative Fair Market Rents for 120 percent of Fair Market Rent (FMR) (increased HCV (2.b.) for one-bedroom units and to 140 expenditures) percent of FMR for all sized accessible

units for tenants requiring those features.

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Reexaminations: The reexamination schedule will Self-Sufficiency Neutral (no cost Alternative change from annual to triennial for all implications) Housing Choice Reexamination households. An interim reexamination Schedule for may be requested once per year when

Households for HCV a 20 percent or more decrease in (3.b.) gross income has occurred. Households without employment income or Social Security benefits

received by heads of household or co-heads of household (zero-income households) will have an interim when new income begins.

Reexaminations: Self The PHA will increase the threshold Cost- Positive

Certification of for the self-certification of assets from Effectiveness (decreased Assets for HCV (3.d.) $5,000 to $25,000. expenditures)

Landlord Leasing Landlords will receive a vacancy loss Housing Choice Neutral Incentives: Vacancy payment of 1 month of contract rent for (increased Loss (4.a.) the most recent lease at the execution revenue and

of a new Housing Assistance Payment increased (HAP) contract. expenditures)

Landlord Leasing Landlords will be eligible to receive Housing Choice Neutral Incentives: Damage payment of up to 1 month of contract (increased Claims (4.b.) rent for damage claims if the cost of revenue and

repairs exceeds the security deposit. increased Payment is made at the execution of a expenditures) new HAP contract.

Landlord Leasing Additional landlord incentives will Housing Choice Neutral Incentives: Other include a referring landlord bonus of (increased

Landlord Incentives $250 for referring a new landlord to the revenue and (4.c.) HCV program that results in a HAP increased contract, a $250 new landlord signing expenditures)

bonus, a $250 new contract bonus, and a one-time security deposit per tenant of up to 1 month of rent. A new landlord is defined as one with no rental history with PHA’s HCV program.

Housing Quality HCV units will be eligible to have a Cost- Neutral (no cost Standards (HQS): prequalifying HQS inspection up to 60 Effectiveness implications) Prequalifying Unit days prior to an HCV recipient’s move-Housing Choice Inspections for HCV in date. (5.a.)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Housing Quality The PHA will create a third-party Cost- Neutral (no cost Standards: Third-inspection collaboration with the Effectiveness implications) Party Requirement Harrisonburg-Rockingham Community (5.c.) Services Board, which has certified

HQS Inspectors on staff.

Project-Based The maximum percent of authorized Cost- Positive Voucher Program HCV units authorized for project-Effectiveness (increased Flexibilities: Increase basing will increase to 50 percent. revenue) Housing choice PBV Program Cap

(9.a.)

Project-Based The PBV cap within a housing project Cost- Positive Voucher Program will increase to 50 percent. Effectiveness (increased Flexibilities: Increase revenue) Housing Choice PBV Project Cap

(9.b.)

Project-Based The PHA will use PBVs to assist in Cost- Positive Voucher Program renovating PHA-owned properties. Effectiveness (decreased Flexibilities: expenditures) Housing Choice Elimination of PBV

Selection Process for PHA-owned Projects Without Improvement,

Development, or Replacement of Public Housing Site (9.c.)

Project-Based Portability will be limited by delaying Cost- Positive

Voucher Program when a household can request to Effectiveness (decreased Flexibilities: Limit move from a PBV to a tenant-based expenditures) Portability for PBV voucher. Households must now have

Units (9.h.) been in the PBV unit at Franklin Heights for 2 years instead of 1 before requesting a tenant-based voucher.

Family Self- The PHA will modify the FSS Contract Self-Sufficiency Neutral (no cost Sufficiency (FSS) of Participation to remove the implications)

Program with MTW traditional escrow model and replace it Flexibility: Modify or with a new Goal Rewards Model. Eliminate the These changes shift the agency-Contract of participant relationship away from rule

Participation for HCV enforcement and toward life coaching. (10.d.)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

FSS Program with The PHA will replace the FSS escrow Self-Sufficiency Neutral (no cost MTW Flexibility: model with a goal rewards model. In implications) Policies for this model, participants earn Addressing immediate cash incentives (via check

Increases in Family or deposit into a PHA-managed Income for public savings account) for reaching housing (10.e.) milestones related to income, finance, education, health, employment, and

other self-sufficiency goals. Income increases will not be used for determining TTP (until the next reexamination) and will not contribute to increases in escrow.

HCV = Housing Choice Voucher. MTW = Moving to Work. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in February 2023 Exhibit B-25(a). Background Information for Brattleboro Housing Authority (VT-002)

Location Brattleboro, Vermont ACC Amendment August 2021 Approval

Programs and HCV: 212 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 284 FY2022: June 2022 units a

Special Purpose Mainstream, S+C Total MTW Waivers 5 Vouchers vouchers Approved

RAD Conversion Yes (PBV) Use of PBVs Yes

ACC = Annual Contributions Contract. FY = fiscal year. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. S+C = Shelter Plus Care. a The PHA reported converting their public housing to project-based vouchers but still has approved waivers for the public housing program. This number reflects the number of public housing units the public housing agency had at the time of Moving to Work designation. Sources: MTW Supplements; interview with PHA in March 2023; HUD communications

Exhibit B-25(b). Approved MTW Waivers as of March 31, 2023, for Brattleboro Housing Authority (VT-002)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Reexaminations: The frequency of reexaminations will Cost- Neutral (no cost Alternative decrease from annual to triennial for all Effectiveness implications)

Reexamination households on fixed incomes. Whenever Schedule for a household’s income drops by more Households for than 10 percent for a period of 30 days public housing or whenever a household’s expenses

(3.a.) increase by 10 percent or more for 30 days, the household may request and Reexaminations: will be given a reexamination. Alternative Households may request interim Reexamination recertifications as needed. Schedule for Households for HCV (3.b.)

Reexaminations: The PHA will increase the threshold for Cost- Neutral (no cost Self Certification the self-certification of assets from Effectiveness implications)

of Assets for $5,000 to $25,000. public housing (3.c.)

Reexaminations:

Self Certification of Assets for HCV (3.d.)

Housing Quality The PHA will modify the inspection Cost- Neutral (no cost Standards: schedule for HCV units to an inspection Effectiveness implications)

Alternative every 3 years. Inspection Schedule for HCV (5.d.)

HCV = Housing Choice Voucher. MTW = Moving to Work. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in March 2023 Exhibit B-26(a). Background Information for Randolph County Housing Authority (WV-045)

Location Elkins, West Virginia ACC Amendment August 2021 Approval

Programs and HCV: 709 units MTW Supplement FY2021: None Inventory Approvals Public Housing: 0 units FY2022: December

2022

Special Purpose FYI, Mainstream, VASH Total MTW Waivers 5 Vouchers Approved RAD Conversion No Use of PBVs Yes ACC = Annual Contributions Contract. FY = fiscal year. FYI = Foster Youth to Independence. HCV = housing choice voucher. MTW = Moving to Work. PBV = project-based voucher. RAD = Rental Assistance Demonstration. VASH = Veterans Affairs Supportive Housing. Sources: MTW Supplements; interview with PHA in March 2023; HUD communications

Exhibit B-26(b). Approved MTW Waivers as of March 31, 2023, for Randolph County Housing Authority (WV-045)

Waiver Statutory Anticipated Description of Planned Change Objectives Effect on PHA Targeted Costs

Tenant Rent The PHA will streamline the utility Cost- Positive Policies: allowance schedules from 24 to 4. The Effectiveness (decreased Alternative Utility schedules will apply to the entire six-expenditures) Allowance for county jurisdiction based on unit size and

HCV (1.j.) type.

Tenant Rent A standard deduction of $2,000 for Cost- Positive Policies: Standard medical expenses will be applied to Effectiveness (decreased Deductions for income calculations for senior and expenditures) HCV (1.u.) disabled tenants.

Reexaminations: Households will be allowed to self-certify Cost- Positive

Self Certification up to $50,000 in assets during the Effectiveness (decreased of Assets for HCV reexamination process. expenditures) (3.d.)

Housing Quality HQS inspections will be allowed to take Cost- Positive Standards (HQS): place before a Request for Tenancy in Effectiveness (decreased

Prequalifying Unit vacant units that landlords expect to be expenditures) Inspections for rented within 15 to 30 days. HCV (5.a.)

Local, The PHA will use up to 10 percent of Housing Choice Neutral (no cost Nontraditional Housing Assistance Payment dollars for implications)

Activities: Housing housing development acquisition funds, Development matching or leveraging dollars for Programs (17.c) competitive funding applications. HCV = Housing Choice Voucher. MTW = Moving to Work. PHA = public housing agency. Sources: MTW Supplement; interview with PHA in March 2023

Appendix C. Exploratory Impact Analysis

This appendix displays the regression-adjusted means for the Treatment and Control groups, estimated program impact (difference in regression-adjusted means), and associated statistical significance for confirmatory and exploratory hypothesis tests. All results are estimated using data from the Treatment PHAs and Control PHAs. Appendix D explains the methodology.

Exhibit C-1. Estimated Impacts on PHA Cost-Effectiveness (Dollars per Household per Month) Outcome Treatment Control Impact p-value Confirmatory Total operating, administrative, and HAP expenditures ($) 730 629 101 0.140

Exploratory Public housing operating expenses minus utilities ($)PH 601 486 115 0.187

HCV and local, nontraditional program administrative and tenant services expenditures ($) HCV 87 74 13 0.084*

HCV HAP expenditures ($)HCV 686 659 26 0.381

Total federal funding of MTW-eligible programs ($) 646 569 73 0.107

Total revenue of MTW-eligible programs ($) 857 712 145 0.053*

Cash reserves ($) 62 42 20 0.468

HAP = Housing Assistance Payment. HCV = Housing Choice Voucher. MTW = Moving to Work. PH Where indicated, means are estimated using only public housing agencies (PHAs) with public housing programs (27 PHAs). HCV Where indicated, means are estimated using only PHAs with voucher programs (38 PHAs). * Statically significant at the p < 0.10 level. Notes: This sample includes 43 public housing agencies (PHAs; 33 Treatment PHAs, 10 Control PHAs). The means reported are the regression-adjusted averages of PHA-level values. The confirmatory measure excludes utility payments from public housing operating expenses. Utilities are excluded from public housing operating costs for a more consistent comparison between PHAs. Some PHAs pay utilities directly, so the cost shows up on Financial Data System (FDS) as operating expenses (these PHAs collect more total tenant [rent] payment, because no utility allowance is provided for tenants); other PHAs do not pay these costs directly so it does not show up on FDS as operating expenses (but collect less in total tenant payment because they do not provide a utility allowance). Exhibit C-1 in the Baseline Report details the construction of the measures in this exhibit (Geyer et al., 2023). Sources: HUD’s FDS (PHA annual fiscal reports through December 2022); Voucher Management System quarterly data

Exhibit C-2. Estimated Impacts on Nonelderly, Nondisabled Household Earnings and Employment and Earnings

Outcome Treatment Control Impact p-value

Confirmatory

Household earnings in most recent year (Q1 2022 to Q4 2022) $23,944 $21,466 $2,478 0.078*

Exploratory

Percentage of households with any earnings in Q4

2022 69.9 72.3 – 2.4 0.363

Among households who exited in 2022, household earnings in most recent year (Q1 2022 to Q4 2022) $27,433 $26,206 $1,226 0.407

Among households who exited assistance in 2022, percentage with household earnings in Q4 2022 equivalent to 2.5 times or more of the local Fair

Market Rent 41.7 40.3 1.5 0.462

Q1 = first quarter. Q4 = fourth quarter.

* Statically significant at the p < 0.10 level. Notes: Of the 8,590 nonelderly, nondisabled households analyzed from the 33 Treatment public housing agencies (PHAs), 3,166 were from the 10 Control PHAs. Households that exited include 2,674 households from the Treatment PHAs and 1,063 from the Control PHAs. Means are regression-adjusted. Exhibit C-2 in the Baseline Report provides details on the construction of the measures in this exhibit. Annual earnings are calculated as the sum of the fourth quarter of 2021 and the first, second, and third quarters of 2022. Sources: National Directory of New Hires earnings data through third calendar quarter of 2022; HUD household-level data from the Housing Information Portal through December 31, 2022

Exhibit C-3. Estimated Impacts on Household Housing Choice: Low-Poverty Rate of Household Census Tracts

Outcome Treatment Control Impact p-value

Confirmatory

Percentage of HCV households living in low-poverty census tracts 33.1 30.7 2.4 0.052*

Exploratory

Percentage of HCV households living in census

tracts with a poverty rate lower than the 25th percentile poverty rate for the PHA’s jurisdiction 26.6 24.4 2.2 0.065*

Percentage of HCV households living in census tracts with a poverty rate below the median for the PHA’s jurisdiction 51.8 50.2 1.6 0.441

Percentage of HCV households with children

living in census tracts with a poverty rate lower than the 25 th percentile poverty rate for the PHA’s jurisdiction 26.8 25.7 1.1 0.569

Percentage of HCV households with children living in census tracts with a poverty rate below

the median for the PHA’s jurisdiction 52.8 53.8 – 1.0 0.736

HCV = housing choice voucher. PHA = public housing agency.

* Statically significant at the p < 0.10 level. Notes: This sample includes 11,675 HCV households in 29 Treatment PHAs and 4,123 HCV households in 8 Control PHAs (the excluded PHAs do not have voucher programs). Means are regression-adjusted. A low-poverty census tract is defined as a census tract with a poverty rate of less than 10 percent or a poverty rate in the lowest quartile of census tract poverty rates for the PHA’s jurisdiction. Exhibit C-3 in the Baseline Report provides details on the construction of the measures in this exhibit. To be consistent with baseline measures, 2019 American Community Survey (ACS) 5-year data were used, because both census tract boundaries (2010 boundaries compared with 2020 boundaries) and poverty rates for a given census tract changed over time. Sources: HUD household-level data from the Housing Information Portal through December 31, 2022; 2019 ACS 5-year data

Exhibit C-4. Estimated Impacts on Household Housing Choice: Public Housing Agency Supply of Quality, Affordable Rental Units

Exploratory Outcome Treatment Control Impact p-value

Total number of households served through HCV and public housing programs in average month 530.0 553.4 23.4 0.283

HCV unit utilization rate (percent)HCV 84.1 83.9 0.3 0.884

HCV budget utilization rate (percent)HCV 98.2 95.1 3.1 0.526

Public housing occupancy rate (percent)PH 72.8 89.8 17.0 0.227

Number of unique HCV landlords (by TIN/SSN) per 100 voucher households HCV 35.1 29.4 – 5.7 0.013**

Public housing units scoring 90 or above on most recent physical inspection (percent) PH 85.3 83.8 1.6 0.439

Economic useful life of public housing units 25.0 24.8 0.2 0.977 (measured as ratio of total capital assets net of

Exploratory Outcome Treatment Control Impact p-value

depreciation, excluding land, and total capital assets including accumulated depreciation) PH HCV = housing choice voucher. TIN = taxpayer identification number. SSN = Social Security number. PH Means are estimated using only public housing agencies (PHAs) with public housing programs (26 PHAs). HCV Means are estimated using only PHAs with voucher programs (38 PHAs). ** Statically significant at the p < 0.05 level. Notes: This sample includes 43 PHAs (33 Treatment PHAs, 10 Control PHAs). The means reported are the regression-adjusted average of PHA-level values. Exhibit C-4 in the Baseline Report provides details on the construction of the measures in this exhibit. Sources: HUD household-level data from the Housing Information Portal through December 31, 2022; HUD Financial Data System (PHA annual fiscal reports through December 2022)

Exhibit C-5. Estimated Impacts on Household Housing Choice, Hard-to-House Populations

Exploratory Outcome Treatment Control Impact p-value

Percentage of households served that have a nonelderly family member with a disability 30.2 30.3 – 0.2 0.821

Percentage of households served that have three or more minors 4.8 5.0 – 0.2 0.552

Percentage of households served that were

homeless at the time of admission 7.2 6.7 0.5 0.673

Notes: Sample size is 16,947 households in the 33 Treatment public housing agencies (PHAs) and 5,992 households in the 10 Control PHAs. Exhibit C-5 in the Baseline Report provides details on the construction of the measures in this exhibit. Source: HUD household-level data from the Housing Information Portal through December 31, 2022

Exhibit C-6. Estimated Impacts on Other Tenant Outcomes: Households Served Exploratory Outcome Treatment ControlImpact p-value Proportion of newly admitted households with income at or below the greater of 30 percent of Area Median Income or the federal poverty level Overall 88.4 93.3 – 4.9 0.135

Public housing 86.0 91.2 – 5.2 0.144

Housing choice vouchers 91.8 92.5 – 0.7 0.846

Number of households served in Moving to Work-eligible programs PHA Overall 526.8 553.9 27.1 0.226

Public housingPH 237.9 243.8 6.0 0.510

Housing choice vouchersHCV 428.0 452.7 24.7 0.346

Percentage of households with at least one child aged < 18

Overall 37.5 38.4 – 0.9 0.317

Public housing 35.9 37.2 – 1.3 0.134

Housing choice vouchers 38.0 39.0 – 1.0 0.434 Percentage of households whose head of household, spouse, or co-head of household is aged < 62 and has a disability Overall 28.1 28.3 – 0.2 0.766

Public housing 23.0 23.3 – 0.4 0.759

Housing choice vouchers 30.0 30.3 – 0.2 0.791

HCV Means are estimated using only public housing agencies (PHAs) with voucher programs (38 PHAs). PH Means are estimated using only PHAs with public housing programs (27 PHAs). PHA Analysis of PHA-level means instead of household-level means. Notes: This sample includes 43 PHAs (33 Treatment PHAs, 10 Control PHAs), with 1,312 new admissions in 2022 in the Treatment PHAs (429 in public housing, 800 with vouchers) and 522 new admissions in the Control PHAs (121 in public housing, and 367 with vouchers). Means are regression-adjusted. Households in the Treatment PHAs included 16,947 households (4,631 in public housing, 12,312 with vouchers) and 5,992 households in the Control PHAs (1,833 in public housing, 4,149 with vouchers). Exhibit C-6 in the Baseline Report provides details on the construction of the measures in this exhibit. Source: HUD household-level data from the Housing Information Portal through December 31, 2022

Exhibit C-7. Estimated Impacts on Other Tenant Outcomes: Households Exit Exploratory Outcome Treatment Control Impact p-value Percentage of households ending participation in past 12 months

Overall 11.2 9.4 1.8 0.283

Public housingPH 13.6 9.9 3.6 0.096*

Housing choice vouchersHCV 8.2 9.2 – 0.9 0.195 Percentage of households ending participation in past 12 months with household income exceeding 2.5 times Fair Market Rent at most recent reexamination Overall 18.3 18.2 0.1 0.950

Public housingPH 16.3 15.0 1.3 0.790

Housing choice vouchersHCV 19.0 20.0 – 0.9 0.706

* Statically significant at the p < 0.10.

HCV Where indicated, means are estimated only using public housing agencies (PHAs) with voucher programs (38 PHAs). PH Where indicated, means are estimated only using PHAs with public housing programs (27 PHAs). Where indicated, means are estimated only using PHAs with voucher programs (38 PHAs). HCV Notes: This sample includes 43 PHAs (33 Treatment PHAs, 10 Control PHAs), with 5,242 public housing households in the Treatment PHAs, 2,053 public housing households in the Control PHAs, 13,557 housing choice voucher (HCV) households in the Treatment PHAs, and 4,681 HCV households in the Control PHAs. Means are regression-adjusted. The percentages are percentages of any household assisted in the calendar year 2022. Exhibit C-7 in the Baseline Report provides details on the construction of the measures in this exhibit. See exhibit C-2 for similar measure using earnings based on National Directory of New Hires data rather than income at most recent reexamination. Source: HUD household-level data from the Housing Information Portal through December 31, 2022

Exhibit C-8. Estimated Impacts on Other Outcomes: Rent Burden in Public Housing Exploratory Outcome Treatment Control Impact p-value Average rent burden in public housing among households not paying minimum rent Overall 27.7 28.8 – 1.1 0.022**

Household with children 26.3 28.3 – 1.9 0.005***

Household headed by a person aged ≥ 62 27.8 28.0 – 0.2 0.569

Household headed by a person aged < 62 with a disability 28.3 28.3 0.0 0.970

Percentage of households in public housing with rent burden above 30 percent among households not paying minimum rent Overall 5.9 8.4 – 2.5 0.001***

Household with children 2.6 6.5 – 3.8 0.000***

Household headed by a person aged ≥ 62 1.0 0.4 0.6 0.038

Household headed by a person aged < 62 with a

disability 0.1 0.6 – 0.5 0.138

Percentage of households in public housing with rent burden above 40 percent among households not paying minimum rent Overall 0.6 2.7 – 2.1 0.016**

Household with children 1.1 4.3 – 3.2 0.002***

Household headed by a person aged ≥ 62 – 0.1 0.5 – 0.5 0.339

Household headed by a person aged < 62 with a disability 0.2 0.2 0.0 0.944

Percentage of households in public housing with rent burden above 50 percent among households not paying minimum rent Overall 0.1 1.7 – 1.6 0.022**

Household with children 0.0 2.6 – 2.6 0.002***

Household headed by a person aged ≥ 62 0.0 0.4 – 0.4 0.322

Household headed by a person aged < 62 with a disability 0.2 0.1 0.1 0.581

Percentage of households in public housing with zero income paying $50 or less in rent Any household 2.9 4.7 – 1.8 0.062* * Statically significant at the p < 0.10 level. ** Statically significant at the p < 0.05 level. *** Statically significant at the p < 0.01 level. Notes: Sample size is 4,631 households in public housing in the Treatment public housing agencies (PHAs) and 1,833 households in public housing in the Control PHAs. Means are regression-adjusted. Rent burden is calculated as the ratio of 12 times the total tenant payment to the household’s unadjusted (gross) annual income, top-coded at 1 (100 percent). Exhibit C-8 in the Baseline Report provides details on the construction of the measures in this exhibit. Source: HUD household-level data from the Housing Information Portal through December 31, 2022

Exhibit C-9. Estimated Impacts on Other Outcomes: Rent Burden in Housing Choice Voucher Program Exploratory Outcome Treatment Control Impact p-value Average rent burden in the HCV program

Overall 32.0 32.3 – 0.3 0.530

Household with children 32.0 33.0 – 1.0 0.235

Households headed by a person aged ≥ 62 28.9 28.7 0.2 0.556

Households headed by a person aged < 62 with a disability 28.9 29.9 – 1.0 0.148

Percentage of households in the HCV program with rent burden above 30 percent Overall 32.0 32.3 – 0.3 0.530

Household with children 32.0 33.0 – 1.0 0.235

Households headed by a person aged ≥ 62 28.9 28.7 0.2 0.556

Households headed by a person aged < 62 with a disability 28.9 29.9 – 1.0 0.148

Percentage of households in the HCV program with rent burden above 40 percent

Overall 6.1 6.5 – 0.4 0.575

Household with children 7.7 9.3 – 1.6 0.204

Households headed by a person aged ≥ 62 1.1 0.7 0.4 0.486

Households headed by a person aged < 62 with a disability 1.0 2.6 – 1.6 0.149

Percentage of households in the HCV program with rent burden above 50 percent Overall 5.7 6.1 – 0.3 0.599

Household with children 7.1 8.4 – 1.3 0.310

Households headed by a person aged ≥ 62 1.0 0.7 0.3 0.585

Households headed by a person aged < 62 with a disability 1.0 2.4 – 1.4 0.131 Notes: Households with vouchers included 12,312 in the Treatment public housing agencies (PHAs) and 4,149 households in the Control PHAs. Means are regression-adjusted. Rent burden is calculated as the ratio of 12 times the total tenant payment to the household’s unadjusted (gross) annual income, top-coded at 1 (100 percent). Exhibit C-8 in the Baseline Report provides details on the construction of the measures in this exhibit. Source: HUD household-level data from the Housing Information Portal through December 31, 2022

Appendix D. Impact Analysis Methodology

This appendix summarizes the methodology for estimating impacts. The methodology deviates from the original plan specified in the Research Design / Data Collection and Analysis Plan (Turnham et al., 2021). The two deviations include—

1. Impacts on housing supply are measured at the public housing agency (PHA) level instead of the household level because housing supply outcomes, such as number of unique landlords per 100 housing choice voucher (HCV) households, are best interpreted at the PHA level.

2. Covariates are omitted for the regression model used to study impacts at the household level. The original plan was to use baseline means as covariates in the regression model, with covariates measured at the PHA-level. Household-level baseline characteristics cannot be used because household entry or exit into the programs may be endogenous, and households that entered the program after 2020 have no observable baseline data.

3. The PHA-level baseline covariates were found to generate unstable results because the regression model was overidentified, yielding wide variances and imprecise estimates.

To make use of the baseline information without using covariates, the household analysis was changed to a difference-in-differences analysis, as the Household-Level Outcomes section explains.

PHA-Level Outcomes

Outcomes related to cost-effectiveness and housing supply were measured at the PHA level. Equation (1) illustrates the linear regression equation planned to estimate for these outcomes. In addition to the treatment and strata variables (that is, geographic region) on the right-hand side, the baseline measure of the outcome is included as a covariate.

The regression model for estimating the impact of having Moving to Work (MTW) designation is—

𝑌𝑌 𝑝𝑝 = 𝛼𝛼 + 𝛿𝛿𝑇𝑇 𝑝𝑝 + 𝛽𝛽𝑌𝑌 𝑝𝑝,𝑡𝑡 = 0 + 𝜃𝜃𝑆𝑆 (Equation 1) 𝑝𝑝 + 𝜀𝜀 𝑝𝑝

where—

Yp is the outcome of interest at PHA p.

Tp is a dummy variable that equals 1 for PHAs in the treatment group and equals 0 for PHAs in the control group. 𝑌𝑌 is the baseline measure of the outcome of interest. 𝑝𝑝 , 𝑡𝑡 = 0

Sp is a series of dummy variables that reflect the geographic stratum. εp is a random error term.

The subscript p indexes PHAs, indicating that the analysis is done at the PHA-level.

The coefficient, δ, provides an Intent to Treat estimate of the impact of having the opportunity to earn MTW designation. In other words, the coefficient, δ, estimates the difference in regression adjusted means between the treatment and control groups.

121 With 43 observations, the number of covariates that can be included in the model is quite limited. Beyond the treatment indicator, geographic strata, and baseline measure of the outcome, including one or two additional baseline measures to further increase the precision of the impact estimate may be included if possible. Household-Level Outcomes

Equation (2) illustrates the linear regression equation planned to estimate the impact of MTW designation on self-sufficiency and housing choice. It is estimated using household-level data from the baseline and followup period.

𝑌𝑌 𝑖𝑖𝑝𝑝 = 𝛼𝛼 + 𝛽𝛽 (Equation 2) 1 𝑇𝑇 𝑝𝑝 + 𝛽𝛽 2 𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃 𝑖𝑖 + 𝛽𝛽 3 𝑇𝑇 𝑝𝑝 𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃 𝑖𝑖 + 𝜀𝜀 𝑖𝑖𝑝𝑝

where—

Yip is the outcome of interest observed in household i at PHA p.

Tp is a dummy variable that equals 1 for PHAs in the treatment group and equals 0 for PHAs in the control group.

Posti is a dummy variable that equals 1 for household-level observations made in the followup period and equals 0 for household-level observations made in the baseline period. β1 controls for baseline-level differences between Treatment PHAs and Control PHAs.

β2 controls for time-trend differences between the baseline and followup periods that affect both Treatment PHAs and Control PHAs in the same way.

β3 is the impact of being offered the opportunity to apply for MTW designation on outcomes in the followup period. 𝜀𝜀 is a cluster (PHA)-robust random error term. 𝑖𝑖𝑝𝑝

The subscript p indexes PHAs and the subscript i indexes households, indicating that the analysis is done at the household level.

References

de Sousa, Tanya, Judy Geyer, Larry Buron, Laura Peck, and Keely Stater. 2023. Evaluation of the Moving to Work Flexibility Cohort: First Year of MTW Flexibility. Washington, DC: U.S. Department of Housing and Urban Development, Office of Policy Development and Research.

Galster, George C., Dave E. Marcotte, Marv B. Mandell, Hal Wolman, and Nancy Augustine. 2007. “The Influence of Neighborhood Poverty During Childhood on Fertility, Education, and Earnings Outcomes,” Housing Studies 22 (5): 723–752.

Geyer, Judy, Tanya de Sousa, Larry Buron, and Laura Peck, Tyler Morrill, Edoardo Ortiz, Cara Sierks, Douglas Walton, and Will Yetvin. 2023. Evaluating MTW Flexibility for Smaller PHAs: Baseline Report. Washington, DC: U.S. Department of Housing and Urban Development, Office of Policy Development and Research. https://www.huduser.gov/portal/publications/Evaluating-MTW-Flexibility-for-Smaller-PHAs-Baseline-Report.html .

Turnham, Jennifer, Larry Buron, Judy Geyer, Tanya de Sousa, and Laura Peck. 2021. Research Design / Data Collection and Analysis Plan: Evaluation of Cohort 1 of the Moving to Work Demonstration Program Expansion . Washington, DC: U.S. Department of Housing and Urban Development, Office of Policy Development and Research. https://www.huduser.gov/portal/sites/default/files/pdf/Evaluation-Cohort1-RDDCAP-2021.pdf .

U.S. Department of Housing and Urban Development (HUD). 2020. VI. Moving to Work Operations Notice . https://www.hud.gov/sites/dfiles/PIH/documents/FinalMTWExOpsNoticePartVIWeb.pdf .

Washington County. 2022. “Washington County Moving to Work Supplement.” https://www.hud.gov/sites/dfiles/PIH/documents/WashingtonCDAFYB22Supplement.pdf.

U.S. Department of Housing and Urban Development

Office of Policy Development and Research

Washington, DC 20410-6000

September 2024

Table of Contents

Chapter 2 describes the challenges that PHAs face in developing MTW Supplements and looks across PHAs to detail how many have received approved MTW Waivers in each category and the specific activities approved in that category. It concludes with PHA-reported lessons learned and recommendations on planning MTW activities.

Chapter 3 discusses how individual Flexibility Cohort PHAs combine MTW Waivers and associated activities to meet one or more of the three MTW statutory objectives.

Chapter 4 describes how Flexibility Cohort PHA plans for MTW Waivers have changed since their MTW application and summarizes recent legislation that provides additional flexibility for PHAs, even if they are not an MTW PHA.

Chapter 5 presents impact estimates of MTW flexibility for the PHAs in the second year after being offered the opportunity to become an MTW PHA. The outcomes are grouped by the three statutory objectives of the program: cost-effectiveness, self-sufficiency, and housing choice. The chapter focuses on the three confirmatory outcomes of the study—the outcomes judged to be the best single measures of whether the PHAs offered MTW flexibility have achieved each statutory objective. Chapter 5 briefly mentions exploratory outcomes, providing a more complete picture of the potential impact of MTW. 9

Chapter 6 discusses the findings of the process study and impact study research questions for the Flexibility Cohort in the second year after being offered the opportunity to become an MTW agency. 1.2 Evaluation Design and Data Sources

Executive Summary ..................................................................................

How Do Smaller Public Housing Agencies Use Moving to Work Flexibility? .............................

What are the Impacts of Moving to Work Flexibility on Smaller Public Housing Agencies and Their

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

1.3 Status of Flexibility Cohort Moving to Work Public Housing Agencies ...........................

2. Moving to Work Supplement Process and Approved Waivers Across Public Housing Agencies .........

2.2 Public Housing Agency Experiences Completing the Moving to Work Supplement ................. 9

2.3 Approved Moving to Work Waivers and Activities Across Public Housing Agencies ............. 11

2.4 Use of Funding Flexibility to Support Moving to Work Activities ...............................

2.5 Public Housing Agencies Without an Approved Moving to Work Supplement ....................... 3

3. Approved Moving to Work Activities by Targeted Moving to Work Objectives ......................

3.2 Approved Public Housing Agency Activities to Promote Cost-Effectiveness .......................

3.3 Approved Public Housing Agency Activities to Promote Self-Sufficiency .........................

3.4 Approved Public Housing Agency Activities to Promote Housing Choice ...........................

3.5 Timeline for Implementing Activities ..........................................................

4. Changes Over Time, Control Group Activities, and Significant Legislation .......................

4.2 Activities Undertaken by Non-Moving to Work Public Housing Agencies (Control Group) ... 49

4.3 Effect of Housing Opportunity Through Modernization Act Changes ...............................

5. Interim Impacts on Outcome Measures ............................................................

5.1 Confirmatory Outcomes .........................................................................

5.2 Exploratory Outcomes ..........................................................................

6. Summary of Findings for Research Questions .....................................................

6.2 What Are the Impacts of Moving to Work Flexibility on Smaller Public Housing Agencies and Their

Appendix A. Maps of Moving to Work Flexibility Cohort Public Housing Agencies and Control Public Hou

Appendix B. Profiles for 26 Flexibility Cohort Public Housing Agencies with Approved Moving to Work

Appendix C. Exploratory Impact Analysis ............................................................

Appendix D. Impact Analysis Methodology ............................................................

References .........................................................................................

Exhibit 2-3. Applying Moving to Work Flexibility to Special Purpose Vouchers .......................

Exhibit 2-4. Approved Activities to Adjust Tenant Rent Policies ....................................

Exhibit 2-5. Approved Activities to Adjust Payment Standards and Rent Reasonableness................

Exhibit 2-6. Approved Activities to Adjust the Reexamination Process ...............................

Exhibit 2-7. Implementing Alternative Reexamination Schedules ......................................

Exhibit 2-8. Approved Activities to Implement Landlord Leasing Incentives ..........................

Exhibit 2-9. How Public Housing Agencies Use Other Landlord Leasing Incentives Waivers .............

Exhibit 2-10. Approved Activities to Adjust Housing Quality Standards Processes ....................

Exhibit 2-11. Approved Activities to Implement Project-Based Voucher Program Flexibilities .........

Exhibit 2-12. Approved Activities to Adjust the Family Self-Sufficiency Program ....................

Exhibit 2-13. Approved Activities to Implement a Moving to Work Self-Sufficiency Program ...........

Exhibit 2-14. Approved Activities to Implement Local, Nontraditional Activities ....................

Exhibit 2-15. Challenges in Transitioning to the New Housing Information Portal ....................

Exhibit 3-2. Administrative Efficiency Activities to Promote Cost-Effectiveness for Public Housing A

Exhibit 3-3. Self-Sufficiency Activities for Public Housing Agencies (PHAs) With Multiple Self-Suffi

Exhibit 3-4. Landlord Incentive Activities for Public Housing Agencies (PHAs) to Promote Housing Cho

Exhibit 3-5. Implementation Timing of Approved Moving to Work Activities ...........................

Exhibit 4-1. Flexibility Cohort Public Housing Agencies’ (PHA) Plans for Moving to Work (MTW) Waiver

Exhibit 5-3. Estimated Impacts of Offering Moving to Work Cohort 1 Designation, Year 2 (2022) ......

Exhibit 5-4. Quarterly Earnings Over Time for Households in Treatment, Control, and Comparison Publi

Exhibit A-1. Map of 31 Moving to Work Flexibility Cohort Public Housing Agencies ...................

Exhibit A-2. Map of 10 Control Group PHAs (Numbered) Relative to Flexibility Cohort PHAs (not Number