Non-Elderly Disabled Category 2 Housing Choice Voucher Program: An Implementation and Impact Analysis. C. Variation in Program Implementation

01/01/2014

Although the NOFA established some national standards for the NED2 program, sites were given broad flexibility in implementing these standards, resulting in diverse implementation protocols across communities. In this section, we explore the variation among sites in terms of how they: (1) collaborated in the HUD application process; (2) trained and educated relevant staff; (3) conducted outreach and recruitment; (4) tracked referrals and assisted applicants with required forms and documents; (5) assisted in housing searches; and (6) adjusted PHA policies to accommodate the special needs of NED2 voucher recipients. Table II.2 provides a snapshot of how the 13 sites differed in these implementation procedures.

1. PHA-HHS/MFP Collaboration in the Application Process

A core requirement of the NED2 program was a partnership between PHAs and their respective state HHS or MFP agencies, designed to apply the knowledge and strengths of each partner to meet the housing and health and social service needs of the NED2-eligible population. In some sites, the NED2 program was built on a previous relationship between the two groups, or on relationships with organizations that maintained close ties with the PHAs. For example, the Texas MFP project director had an existing relationship with the state housing finance agency; the Ohio MFP program maintained strong ties to the state PHA association; and the Maryland MFP program has had a longstanding partnership with the Coordinating Center, a non-profit organization that provides transition coordination for the state MFP program, but also works closely with the state's PHAs on housing issues for people with disabilities. These existing connections were regarded as assets during the application development process and throughout program implementation. In other states, however, the relationships between the housing and HHS/MFP teams before the NOFA was released were weak or non-existent, particularly in California, Georgia, and Washington (at the local level, if not the state level). Because staff in these states were not familiar with each other or with each other's rules and processes, more time had to be spent sorting out respective roles and responsibilities.

Perhaps equally important was the extent to which the PHAs that had been awarded vouchers were familiar or had experience with the NED and/or institutionalized population. Although all had at least some experience serving disabled or special needs populations, none reported significant experience with serving people residing in institutions; thus, they needed to rely heavily on their HHS/MFP partners to identify and address the complex needs of the NED2 population. Even without direct experience with institutional residents, some PHAs may have applied lessons learned from extensive experience serving people with disabilities and special needs. Baltimore City, for example, entered into a consent decree in 2005 that required the creation of 1,850 new housing opportunities for non-elderly persons with disabilities.15 This experience resulted in increased awareness among PHA staff there of the complex medical needs of the NED population and strengthened the PHA's relationship with state disability advocates.

Upon release of the NOFA, HHS/MFP project teams in each state reached out to their state's network of PHAs both to generate and determine the level of interest in pursuing the NED2 voucher program. The Washington MFP program, which did not have a previous relationship with the individual PHAs, organized a statewide meeting in advance of the NOFA and took steps to begin drafting a memorandum of understanding (MOU) to demonstrate a partnership between housing and HHS/MFP agencies and indicate how referrals would be made. Similarly, the PHA in Orange County proactively began work on an MOU prior to the NOFA release. In an effort to encourage widespread interest in the voucher program, the Georgia HHS/MFP team coordinated a first-of-its-kind state Medicaid/housing forum, with representatives from all of the state's PHAs. The MFP team in Maryland asked its collaborator, the Coordinating Center, to assemble a task force to identify resources for putting together the application and to determine if the state had the necessary infrastructure to pursue the program. States believed these early efforts helped strengthen their applications and forged relationships they could take advantage of in the future.

After initial efforts to encourage application submissions, most HHS/MFP teams remained in close contact with interested PHAs and played a significant role in the application development and submission process. In two states, however--Georgia and California--the MFP teams were unaware of which PHAs ultimately applied, despite the early efforts to promote submission. The state MFP staff in California was surprised to discover that the PHA in Pasadena had applied without having identified a local MFP lead partner agency in its application. That experience contrasted with, for example, that of Massachusetts, where the HHS team wrote selected sections of the PHA's application. Program representatives in ten of the 13 sites recalled the states' HHS/MFP teams having participated in estimating the number of vouchers to include in their applications. All PHAs except Pasadena collaborated with the HHS/MFP team in developing the MOU, although it was not required by the NOFA. The MFP staff in Washington, however, noted that the draft MOU in the original application was not finalized until after the announcement of awards to specific PHAs.

The NOFA required each applicant to base its request for NED2 vouchers on a reasonable projection of the number of individuals who would be eligible for and in need of the vouchers, using estimates by the HHS/MFP team. The state MFP programs may not have had sufficient local data available to calculate useful estimates, however. In Georgia, where vouchers were needed across the state and some PHAs had rules restricting voucher "porting" during the first year,16 the MFP team had hoped HUD would award just a few vouchers to the 5-6 PHAs interested in applying for them to distribute across the state. Instead, the Decatur PHA application requested 35 vouchers; the state MFP team believed this was more than was needed, and the excess contributed to Decatur's lower voucher utilization rate.

2. Initial Efforts to Inform and Educate Relevant Staff

Upon announcement of the voucher awards, states took action to begin setting up their programs, with notable delays occurring in two of them: California and Georgia. The MFP teams in both noted a delay in finding out which PHAs were awarded vouchers, which may have been due to high-level staffing changes within the two state MFP programs. Regardless of the reason, the result was delays in training and preparation of MFP staff. In California, local MFP agencies were not involved in the Pasadena PHA application, so more effort was required to develop relationships with local MFP partner agencies; this also delayed recruitment of potential voucher applicants.

The other six states moved quickly to set up face-to-face meetings, workshops, and "get-to-know-you" seminars between PHA and HHS/MFP staff, and to establish or refine the referral process. Washington and Ohio both relied on HHS/MFP-funded housing specialists to play a central role, engaging and training transition coordinators on housing issues and educating PHA staff about transition services. These initial education efforts were considered essential, but took several months to establish. For this reason, said Washington, which created an extensive cross-agency communication network between the HHS/MFP staff and the five awarded PHAs, its NED2 program was not fully operational until August 2011, six months after the vouchers were announced.

3. Outreach to and Recruitment of Potential Applicants

To recruit applicants, all sites first sought to identify eligible candidates on existing HCV waiting lists, as required by HCV program regulations. After that, HHS/MFP transition coordinators or case managers in each state or region were primarily responsible for identifying additional eligible applicants. Although HUD said referrals could originate with organizations other than the HHS/MFP partner, few states reported referrals obtained this way. One that did was Massachusetts, where Centers for Independent Living were strongly encouraged to make such referrals, although all referrals had to go through one of three state agencies before submission to the Lynn PHA (see next section for further details). The Ohio MFP team said responses to Section Q of the Minimum Data Set (MDS) Resident Assessment Instrument were a useful source for identifying potential applicants in the Cincinnati area.17 In most states, PHA staff indicated their HHS/MFP counterparts were successful in identifying potential applicants.

A few sites reported a shortage of referrals, at least initially. Washington, for example, reported few referrals early on, which led the team to intensify efforts to educate transition coordinators and case managers about the program and its eligibility criteria. Similarly, after receiving few referrals in Baltimore County in the early stages of the program, the team regrouped and developed an enhanced outreach effort that ultimately led to an increase in referrals. In both cases, staff at the PHAs and the HHS/MFP program worked together to identify the problem and develop a solution.

Similar shortages of referrals occurred in Decatur and Orange County, but in contrast to Washington and Baltimore, both of these situations were attributed to staffing shortages. In Georgia, identifying potential applicants was the primary responsibility of the MFP transition coordinator assigned to the Decatur area, as well as the MFP statewide housing specialist. But from fall 2011 through much of 2012, the MFP program in Georgia had neither a housing specialist nor a project director, and the remaining team members were unable to devote adequate resources to the NED2 program. As a result, the PHA received an insufficient number of referrals.

Similarly, by the end of 2011, the PHA in Orange County stopped receiving referrals from their assigned local MFP partner. The agency was reportedly under a hiring freeze and unable to assign sufficient resources to MFP or the NED2 program. Concerned they would not receive an adequate number of referrals, the PHA team began working directly with the state core MFP team, TAC, and their local HUD office to find a solution. It was eventually determined that the PHA could receive referrals from local MFP agencies in surrounding areas, as long as the PHA kept the assigned lead agency informed about the referrals received. This protocol was officially adopted in early 2012, after the initial January 2012 HUD deadline, and resulted in increased referrals.

4. Referrals, Application Assistance, and Tracking

The NOFA did not provide specific guidelines for how applicants should be referred between the HHS/MFP team and the assigned PHA, the level or type of assistance to be provided to individuals in completing applications, or how the status of referrals and applications should be tracked.

In all sites, the HHS/MFP transition coordinator or case manager was responsible for helping the applicant complete the voucher application and collect the necessary documentation, with varying levels of assistance and involvement from PHA staff. The PHA in Austin, for example, often assisted the MFP team in collecting the necessary information for the application, and frontline staff at the two organizations communicated with each other several times a week regarding active applications. In contrast, the MFP program in Washington funded three regional housing specialists who were assigned the task of coordinating, collecting, and reviewing the NED2 applications from local transition coordinators so PHA staff could be confident the applications they received met HUD and PHA requirements and would be approved quickly.

In some sites, notably Austin, Decatur, Orange County, and Pasadena, the applications were forwarded to the PHA directly from individual transition coordinators, whereas in all other sites, a point person was assigned to review and coordinate submissions. In Ohio, for example, transition coordinators submitted completed applications to the MFP statewide housing specialist, who reviewed and forwarded each to the appropriate PHA, essentially acting as the single point of contact between the MFP field staff and the PHAs. New Jersey, with its single statewide housing agency, adopted a similarly centralized and streamlined approach. For each of the three target population groups, the state identified a statewide point person responsible for working with the transition coordinators in finalizing the application package before forwarding it to the MFP statewide housing coordinator, who would review the application for quality assurance before sending it to the PHA for yet another round of review and approval. Once approved by the PHA, the application would then be passed down to the local PHA field office for processing. Team members in these states--HHS/MFP and PHA staff alike--believed these types of centralized and highly coordinated approaches helped ensure applications were completed in a standardized manner, with gaps or problems quickly identified and resolved.

Except for those in California and Georgia, all state teams described regular and frequent communication between PHA and HHS/MFP staff about the status of referrals and applications. Maryland, Massachusetts, and Washington all adopted an approach similar to that of New Jersey and Ohio, described above, in which a single point of contact was responsible for ensuring applications were complete and tracking the status of all referrals and applications. This arrangement also made it possible to identify problems or breakdowns in communication. In Ohio, for example, the Lucas County PHA was initially less engaged in the process than the PHA in Cincinnati; as a result, applications in Lucas County took longer to process in the early stages of the program. The statewide housing specialist assigned to oversee NED2 operations subsequently made additional efforts to reach out and engage staff at the Lucas PHA, ultimately improving communication and overall workflow. In contrast, the PHAs in Decatur and Orange County both noted long periods of no communication with the MFP team.

Following approval of any voucher application, PHAs are required to conduct a briefing with the individual receiving the voucher to explain rules and responsibilities. In Lynn and Decatur, the PHA staff typically contacted the applicant directly to set up an appointment. In the other sites, however, staff typically contacted the assigned transition coordinator or case manager to help coordinate the appointment. HCV guidelines require these briefings to take place in the PHA office, unless there is a reasonable accommodation request. Only Decatur and Cincinnati reported that all briefings took place at the PHA office. In all other sites, briefings were reported as having taken place in the nursing facility or over the phone. Many of these PHAs indicated that, over time, they became more flexible in making these alternatives the norm (see later section on PHA policies).

Except for those in California and Georgia, all state HHS/MFP staff maintained a central database/tracking system of referrals. In Washington, for example, the MFP team created a statewide database into which all applicant and referral information would be entered directly by transition coordinators or case managers. This allowed for broad statewide tracking and made it easy to identify potential problems. Centralized tracking spreadsheets, also used in Maryland, Massachusetts, New Jersey, Ohio, and Texas, were the centerpiece of regular meetings (ranging from weekly to monthly) between HHS/MFP and PHA staff. In Georgia, because of the MFP staffing shortages noted earlier, and in California, because of the decentralized structure of the state MFP program (PHAs worked directly with local MFP lead agencies with minimal involvement of the state MFP team), little or no regular communication or tracking of referrals took place.

5. Housing Search Assistance

PHA staff in all sites indicated that, upon application approval, a case was referred back to the transition coordinator or case manager for assistance with finding a suitable home. Except for those in Georgia and California, all state transition teams included either a single statewide housing specialist or a network of regional specialists to assist with the housing search. Although the Georgia MFP program included a statewide housing specialist position, the position was vacant from September 2011 through much of 2012. Furthermore, staff at the Decatur PHA operated on the belief that the participant was responsible for seeking out assistance and did not necessarily contact the assigned transition coordinator upon approval. Because of the lack of regular communication between the PHA and MFP team in this state, it is unclear whether voucher recipients always received adequate and/or timely assistance. Finally, during the review period, California did not have a statewide housing specialist position, and local MFP lead agencies were not required to have in-house housing specialists of their own.

6. PHA Special Accommodation Policies for the NED2 Program

The NOFA indicated that PHAs should abide by standard policies established under other HCV programs, which included detailed procedures for responding to reasonable accommodation requests and did not specify any significant adjustments for the NED2 program. It became obvious, however, that many policies governing voucher use--specifically, portability, voucher expiration, and applicant briefing protocol--would need to be amended for the NED2 population to include provisions allowing for, or requiring, special accommodation for people with disabilities.18 Some PHAs, in consultation with their HHS/MFP partners, adopted rules specific to NED2 vouchers from the beginning, whereas most others modified their rules during the project period. Table II.3 details the policies each PHA ultimately adopted for the NED2 voucher program. We examine each of the three policy areas individually.

TABLE II.3. PHA Policies Governing NED2 Housing Choice Vouchers
State Site Portabilitya   Voucher Expiration for NED2 Program   Applicant Briefings
Most Vouchers Issued and Leased Within the First Year of NED2 Program (>85%)
New Jersey New Jersey Statewide portability 60 days + 2 30-day extensions Unknown
Maryland Baltimore City Allowed immediate portability Standard time frames waived Off site
Washington Snohomish County   Evolved to immediate portability   120 days Off site, phone
All Vouchers Issued and Leased by Summer 2012 (100%), but Not Within the First Year of NED2 program
Maryland Baltimore County Allowed immediate portability Standard time frames waived Off site
Massachusetts   City of Lynn Evolved to statewide portability 60 days + 60-day extensions Off site
Ohio City of Cincinnati Allowed immediate portability Open extensions granted Only on-site briefings
Lucas County Allowed immediate portability Open extensions granted Unknown
Washington City of Tacoma Evolved to immediate portability 120 days Off site, phone
City of Longview Evolved to immediate portability 120 days Off site, phone
Fewest Vouchers Issued and Leased Within the First Year of NED2 Program (<60%) and by Summer 2012 (<85%)
California Orange County Allowed immediate portability 120 days + one 60-day extension   Phone
City of Pasadena Immediate porting not permitted Open extensions granted Off site with MFP staff  
Georgia City of Decatur Immediate porting not permitted 60 days + open extensions Only on-site briefings
Texas City of Austin Immediate porting not permitted 120 days Off site
SOURCE: Mathematica analysis of information obtained from PHA and HHS/MFP staff.
NOTE:
  1. Portability refers to the transfer of a housing voucher from one PHA jurisdiction to another.

a. Portability

HUD HCV regulations instruct PHAs to permit the porting of a voucher, which allows individuals to move, or "port," their vouchers from the issuing PHA to a PHA in another region where they wish to live or can find more suitable housing. For applicants who do not live in the PHA's jurisdiction at the time of application, HUD regulations allow the PHA to require use of the voucher for 12 months in that jurisdiction before permitting portability. Through a webinar hosted by the TA providers in July 2011, HUD clarified that voucher recipients could, in fact, exercise immediate portability, but only if permitted by the PHA. The housing agency in New Jersey operates a statewide system with regional branches; thus, porting vouchers is an easy and common process there. Both Maryland's and Ohio's PHAs also indicated they would permit a NED2 voucher holder to port the voucher immediately upon issuing. Several PHAs in other states, however, indicated they would have welcomed an earlier acknowledgement by HUD that this was allowable. Several also noted that they faced a financial disincentive to port the vouchers and were reluctant to adopt open porting policies.19 The PHAs in Washington and in Lynn, for example, originally established a no-porting policy; however, they both became more lenient over time, with the Lynn PHA eventually adopting a statewide porting policy for the vouchers.

Both Austin and Decatur maintained a no-immediate-porting policy throughout the life of the program. The Austin PHA, in consultation with its MFP partner, considered loosening the porting rules, but ultimately decided against amending its policy due to the financial disincentive and because it had received few requests to port. The Decatur PHA would only permit a voucher to be ported after 12 months of residency within its jurisdiction; as mentioned above, this was the standard policy under the HCV program, but the Georgia MFP team felt it was a hindrance to making referrals, since few participants wanted to move to the Decatur area. In early 2012, the California MFP team began consulting with the regional HUD office and TAC to establish open portability rules that would allow participants to use vouchers freely throughout the state. This policy would have been particularly helpful to the Orange County PHA, which was receiving very few local referrals, but for unknown reasons, it was never adopted.

b. Voucher expiration

Per the NOFA, HUD required a 60-day minimum expiration between voucher issuance and voucher leasing. While no maximum term was established by program regulations, HUD encouraged PHAs to approve longer terms as a reasonable accommodation for this population. All PHAs allowed for an expiration period that went beyond the standard for other voucher programs by either allowing extensions or waiving a time frame altogether. Although several PHAs set a limit for the number of extensions that would be permitted, issued vouchers actually expired only in Orange County. Those vouchers, which often expired due to failure to locate acceptable housing after several extensions, were rescinded, and the referral process was required to start over.

c. Applicant briefings

All voucher recipients are required to be briefed on the details of the voucher program and on their responsibilities. For other HCV programs, recipients attend these briefings in person at the PHA office. For the NED2 population, however, for whom mobility is often a concern, traveling to the PHA for these sessions can be a challenge or even impossible. The PHAs in Decatur and Cincinnati maintained their requirement for potential voucher recipients to attend briefings at the PHA office (with exceptions made upon receipt of a reasonable accommodation request), but all other PHAs adjusted their policies to promote the holding of briefings at the nursing facility or over the phone. A few PHAs even allowed MFP staff to conduct the briefings by proxy.

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