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Moving to Work Amended Supplement Upcoming Public Hearing Notice

Date Posted: 12/27/2024
Category: Moving to Work (MTW)

Notice

Spartanburg Housing announces a 45-day comment period beginning on January 2, 2025, and ending February 18, 2025, to solicit suggestions concerning the amendment to Spartanburg Housing Fiscal Year 20225 Moving to Work (MTW) Supplement.

A copy of the document may be accessed at the following website: spartanburghousing.org

Hard copy versions may be reviewed at the following locations:

  • Spartanburg Housing Administrative Office - 170 Arch Street, Spartanburg, SC 29303 between the hours of 8:30 AM - 5:00 PM, Monday through Thursday, and 8:30 AM - 12:00 PM on Friday.
  • Spartanburg Public Library - 151 Church Street, Spartanburg, SC
  • Spartanburg Housing Properties

A public hearing will be held through Zoom on Wednesday, February 19, 2025, at 2:00 PM. Webinar ID: 901 628 3894

The hearing will review the proposed amendment to the MTW Supplement. Public testimony will be given on the plans, and interested parties will be able to provide oral comments.

Written Comments may be submitted to:

Spartanburg Housing
Attention: Meridith Vachon, Strategic Initiatives Coordinator
170 Arch Street
Spartanburg, SC 29303

OR

info@spartanburghousing.org
Subject Line: Moving to Work (MTW) Supplement

Moving to Work Fiscal Year 2025 Amended Supplement - Please contact our office to review the MTW Supplement.

PHA Name : Housing Authority Of Spartanburg
PHA Code : SC003
MTW Supplement for PHA Fiscal Year Beginning : (MM/DD/YYYY): 10/1/2024
PHA Program Type: Combined
MTW Cohort Number: Landlord Incentives
MTW Supplement Submission Type: Amended Annual Submission

B. MTW Supplement Narrative

  • Spartanburg Housing is the fourth largest housing authority in South Carolina and serves over 6,500 residents within Spartanburg County. Our vision continues to surround improving the quality of life through housing by enhancing economic mobility for the families we serve, strengthening communities, and creating strategic partnerships. In collaboration with our community partners, Spartanburg Housing will support families as they move toward self-sufficiency. Spartanburg Housing will use the public housing and housing choice flexibility to best meet the local needs and implement our initiatives. Spartanburg Housing would like to use the MTW flexibility to help address economic mobility. The families we serve often have the fewest opportunities to move up the economic ladder. We will work with our community partners to provide more targeted education and workforce preparation and collaborate to help families gain greater mobility.
  • Spartanburg Housing has focused on implementing landlord incentives (damage claims, vacancy loss payments, and other landlord incentives). These initiatives will address cost-effectiveness by increasing utilization; and self-sufficiency by providing incentives for new landlords and increasing the number of families that can find suitable housing; and housing choices by expanding the number of available housing options for voucher holders. We have implemented biennial recertification for all households in which all household members are 62 and older or the Head of Household, Co-Head, or Spouse is disabled for public housing and the choice voucher program. We are working on implementing the elimination of utility reimbursements for public housing and housing choice voucher programs.
  • With this amendment we are working on implementing a work requirement for our public housing residents. This program will be for public housing non-disabled residents aged 21-55 only at this time.

C. The policies that the MTW agency is using or has used (currently implement, plan to implement in the submission year, plan to discontinue, previously discontinued).

  1. Tenant Review Policies
    1. Tiered Rent (PH) - Not Currently Implemented
    2. Tiered Rent (HCV) - Not Currently Implemented
    3. Stepped Rent (PH) - Not Currently Implemented
    4. Stepped Rent (HCV) - Not Currently Implemented
    5. Minimum Rent (PH) - Not Currently Implemented
    6. Minimum Rent (HCV) - Not Currently Implemented
    7. Total Tenant Payment as a Percentage of Gross Income (PH) - Not Currently Implemented
    8. Total Tenant Payment as a Percentage of Gross Income (HCV) - Not Currently Implemented
    9. Alternative Utility Allowance (PH) - Not Currently Implemented
    10. Alternative Utility Allowance (HCV) - Not Currently Implemented
    11. Fixed Rents (PH) - Not Currently Implemented
    12. Fixed Subsidy (HCV) - Not Currently Implemented
    13. Utility Reimbursements (PH) - Currently Implementing
    14. Utility Reimbursements (HCV) - Currently Implementing
    15. Initial Rent Burden (HCV) - Not Currently Implemented
    16. Imputed Income (PH) - Not Currently Implemented
    17. Imputed Income (HCV) - Not Currently Implemented
    18. Elimination of Deduction(s) (PH) - Not Currently Implemented
    19. Elimination of Deduction(s) (HCV) - Not Currently Implemented
    20. Standard Deductions (PH) - Not Currently Implemented
    21. Standard Deductions (HCV) - Not Currently Implemented
    22. Alternative Income Inclusions/Exclusions (PH) - Not Currently Implemented
    23. Alternative Income Inclusions/Exclusions (HCV) - Not Currently Implemented
  2. Payment Standards and Rent Reasonableness
    1. Payment Standards-Small Area Fair Market Rents (HCV) - Not Currently Implemented
    2. Payment Standards-Fair Market Rents (HCV) - Not Currently Implemented
    3. Rent Reasonableness-Process (HCV) - Not Currently Implemented
    4. Rent Reasonableness-Third-Party Requirement (HCV) - Not Currently Implemented
  3. Re-Examinations
    1. Alternative Reexamination Schedule for Households (PH) Currently Implementing
    2. Alternative Reexamination Schedule for Households (HCV) Currently Implementing
    3. Self-Certification of Assets (PH) Not Currently Implemented
    4. Self-Certification of Assets (HCV) Not Currently Implemented
  4. Landlord Leasing Incentives
    1. Vacancy Loss (HCV-Tenant-based Assistance) - Currently Implementing
    2. Damage Claims (HCV-Tenant-based Assistance) - Currently Implementing
    3. Other Landlord Incentives (HCV- Tenant-based Assistance) - Currently Implementing
  5. Housing Quality Standards (HQS)
    1. Pre-Qualifying Unit Inspections (HCV) Not Currently Implemented
    2. Reasonable Penalty Payments for Landlords (HCV) Not Currently Implemented
    3. Third-Party Requirement (HCV) Currently Implementing
    4. Alternative Inspection Schedule (HCV) Not Currently Implemented
  6. 6. Short-Term Assistance
    1. Short-Term Assistance (PH) Not Currently Implemented
    2. Short-Term Assistance (HCV) Not Currently Implemented
  7. Term-Limited Assistance
    1. Term-Limited Assistance (PH) Not Currently Implemented
    2. Term-Limited Assistance (HCV) Not Currently Implemented
  8. Increase Elderly Age (PH & HCV)
    1. Increase Elderly Age (PH & HCV) Not Currently Implemented
  9. Project-Based Voucher Program Flexibilities
    1. Increase PBV Program Cap (HCV) Not Currently Implemented
    2. Increase PBV Project Cap (HCV) Not Currently Implemented
    3. Elimination of PBV Selection Process for PHA-owned Projects Without Improvement, Development, or Replacement (HCV) Not Currently Implemented
    4. Alternative PBV Selection Process (HCV) Not Currently Implemented
    5. Alternative PBV Unit Types (Shared Housing and Manufactured Housing) (HCV) Not Currently Implemented
    6. Increase PBV HAP Contract Length (HCV) Not Currently Implemented
    7. Increase PBV Rent to Owner (HCV) Not Currently Implemented
    8. Limit Portability for PBV Units (HCV) Not Currently Implemented
  10. Family Self-Sufficiency Program with MTW Flexibility
    1. PH Waive Operating a Required FSS Program (PH) Not Currently Implemented
    2. HCV Waive Operating a Required FSS Program (HCV) Not Currently Implemented
    3. PH Alternative Structure for Establishing Program Coordinating Committee (PH) Not Currently Implemented
    4. HCV Alternative Structure for Establishing Program Coordinating Committee (HCV) Not Currently Implemented
    5. PH Alternative Family Selection Procedures (PH) Not Currently Implemented
    6. HCV Alternative Family Selection Procedures (HCV) Not Currently Implemented
    7. PH Modify or Eliminate the Contract of Participation (PH) Not Currently Implemented
    8. HCV Modify or Eliminate the Contract of Participation (HCV) Not Currently Implemented
    9. PH Policies for Addressing Increases in Family Income (PH) Not Currently Implemented
    10. HCV Policies for Addressing Increases in Family Income (HCV) Not Currently Implemented
  11. MTW Self-Sufficiency Program
    1. PH Alternative Family Selection Procedures (PH) Not Currently Implemented
    2. HCV Alternative Family Selection Procedures (HCV) Not Currently Implemented
    3. PH Policies for Addressing Increases in Family Income (PH) Not Currently Implemented
    4. HCV Policies for Addressing Increases in Family Income (HCV) Not Currently Implemented
  12. Work Requirement
    1. Work Requirement (PH) Plan to Implement in the Submission Year
    2. Work Requirement (HCV) Not Currently Implemented
  13. Use of Public Housing as an Incentive for Economic Progress (PH)
    1. Use of Public Housing as an Incentive for Economic Progress (PH) Not Currently Implemented
  14. Moving on Policy
    1. Waive Initial HQS Inspection Requirement (HCV) Not Currently Implemented
    2. PH Allow Income Calculations from Partner Agencies (PH) Not Currently Implemented
    3. HCV Allow Income Calculations from Partner Agencies (HCV) Not Currently Implemented
    4. PH Aligning Tenant Rents and Utility Payments Between Partner Agencies (PH) Not Currently Implemented
    5. HCV Aligning Tenant Rents and Utility Payments Between Partner Agencies (HCV) Not Currently Implemented
  15. Acquisition without Prior HUD Approval (PH)
    1. Acquisition without Prior HUD Approval (PH) Not Currently Implemented
  16. Deconcentration of Poverty in Public Housing Policy (PH)
    1. Deconcentration of Poverty in Public Housing Policy (PH) Not Currently Implemented
  17. Local, Non-Traditional Activities
    1. Rental Subsidy Programs Not Currently Implemented
    2. Service Provision Not Currently Implemented
    3. Housing Development Programs Not Currently Implemented

C. MTW Activities Plan that Housing Authority Of Spartanburg Plans to Implement in the Submission Year or Is Currently Implementing

1.m. - Utility Reimbursements (PH)
Describe the MTW activity, the MTW agency's goal(s) for the MTW activity, and, if applicable, how the MTW activity contributes to a larger initiative

  • Spartanburg Housing plans to eliminate utility reimbursements to reduce costs while achieving greater cost-effectiveness in expenditures and encouraging family self-sufficiency. The waiver would result in cost savings and a reduction in administrative burdens. It will also help ensure that residents contribute towards their rental payment or, at minimum, do not receive a payment for assistance from Spartanburg Housing. We will eliminate the utility reimbursement by doing the following. If a utility allowance is greater than the total tenant payment, the tenant rent will be zero ($0) and no utility reimbursement will be provided to the tenant.
  • For FY2023 the department paid a total of $1,999.00 to a total of 2 families at Cambridge Place. The average URP check was $133.26. Add on the cost of processing the URP check and the total amount paid out for FY2023 for utility reimbursement was $2,017.15.
  • For FY2023 the department paid a total of $1,099.00 to a total of 20 families at Prince Hall Apartments. The average URP check was $8.27. Add in the cost of processing the URP check and the total amount paid out for the FY2023 for utility reimbursement was $1,156.62.
  • The activity was approved by the field office with the 10/1/23 Amended Moving to Work Supplement. Implementation will start October 1, 2024 new admission families or families currently on the program will not be eligible for the URP payments. A certification will be completed effective June 1, 2025 for families that currently receive the URP payments that will eliminate the payment.

Which of the MTW statutory objectives does this MTW activity serve?

  • Cost effectiveness; Self-sufficiency

What are the cost implications of this MTW activity? Pick the best description of the cost implications based on what you know today?

  • Decreased expenditures

Does the MTW activity under this waiver apply to all assisted households or only to a subset or subsets of assisted households?

  • The MTW activity applies to all assisted households

Based on the Fiscal Year goals listed in the activity's previous Fiscal Year's narrative, provide a description about what has been accomplished or changed during the implementation.

  • Not applicable

1.n. - Utility Reimbursements (HCV)
Describe the MTW activity, the MTW agency's goal(s) for the MTW activity, and, if applicable, how the MTW activity contributes to a larger initiative

  • Spartanburg Housing plans to eliminate utility reimbursements to reduce costs while achieving greater cost-effectiveness in expenditures and encouraging family self-sufficiency. The waiver would result in cost savings and a reduction in administrative burdens. It will also help to ensure that residents are contributing towards their rental payment or at minimum not receiving a payment for receiving assistance from Spartanburg Housing. We will eliminate the utility reimbursement by doing the following. If a utility allowance is greater than the total tenant payment, the tenant rent will be zero ($0) and no utility reimbursement will be provided to the tenant.
  • For FY2023, the department paid a total of $606,001 to a total of 475 families. The average URP check was $102.79. Add in the cost of processing the URP check and the total amount paid out for FY2023 for utility reimbursement is $6110,561.
  • Taking the current Price Per Unit (PUC) into account of $568, if we eliminate the utility reimbursement we could help close to 90 more families find housing.
  • This activity was approved by the field office with the 10/1/23 Amended Moving to Work Supplement. Implementation will start October 1, 2024 new admissions and families currently on the program will not be eligible for URP payments. A certification will be completed effective June 1, 2025 for the families that receive URP payments eliminating the payment.

Which of the MTW statutory objectives does this MTW activity serve?

  • Cost effectiveness; Self-sufficiency

What are the cost implications of this MTW activity? Pick the best description of the cost implications based on what you know today.

  • Decreased expenditures

Does the MTW activity under this waiver apply to all assisted households or only to a subset or subsets of assisted households?

  • The MTW activity applies to all assisted households

Based on the Fiscal Year goals listed in the activity's previous Fiscal Year's narrative, provide a description about what has been accomplished or changed during the implementation.

  • Not applicable

3.a. - Alternative Reexamination Schedule for Households (PH)
Describe the MTW activity, the MTW agency's goal(s) for the MTW activity, and, if applicable, how the MTW activity contributes to a larger initiative

  • Spartanburg Housing will implement biennial recertification for all households in which all members of the household are 62 and older or the Head of Household, Co-Head or Spouse is disabled, even if the household members have earned income, they will be recertified only on a biennial basis. To achieve the highest level of operation efficiency, Spartanburg Housing will stagger the implementation of this activity. All certifications completed in 2024, started in January 205 we will begin the staggering of the odd months making their next annual certification due in 2027. In February 2026 we will start the even month recertification, making their next recertification due in 2028.
    • 2025 Recertification
      • Jan 2025 (Next Reexam 2027)
      • Feb 2025 (Feb 2026)
      • Mar 2025 (Mar 2027)
      • Apr 2025 (Apr 2026)
      • May 2025 (May 2027)
      • Jun 2025 (Jun 2026)
      • Jul 2025 (Jul 2027)
      • Aug 2025 (Aug 2026)
      • Sep 2025 (Sep 2027)
      • Oct 2025 (Oct 2026)
      • Nov 2025 (Nov 2027)
      • Dec 2025 (Dec 2026)
  • For households, listed above: one interim adjustment per year may be requested by the household if the household gross income has decreased 10% or more. Interim recertification for income increases will be limited to a change of $500 or more per month. Increases of income less than $500 per month are required to be reported, but no interim will be completed.
  • All other households and family types will recertify annually.

Which of the MTW statutory objectives does this MTW activity serve?

  • Cost effectiveness; Self-sufficiency

What are the cost implications of this MTW activity? Pick the best description of the cost implications based on what you know today.

  • Decreased expenditures

Does the MTW activity under this waiver apply to all assisted households or only to a subset or subsets of assisted households?

  • The MTW activity applies only to a subset or subsets of assisted households

Does the MTW activity apply only to new admissions, only to currently assisted households, or to both new admissions and currently assisted households?

  • New admissions and currently assisted households

Does the MTW activity apply to all family types or only to selected family types?

  • The MTW activity applies only to selected family types

Please select the family types subject to this MTW activity.

  • Elderly families; Disabled families (to the extent those families are not exempt via a reasonable accommodation)

Does the MTW activity apply to all public housing developments?

  • The MTW activity applies to all developments

Based on the Fiscal Year goals listed in the activity's previous Fiscal Year's narrative, provide a description about what has been accomplished or changed during the implementation.

  • Not applicable

Does this MTW activity require a hardship policy?

  • Yes
  • This document is attached.

Does the hardship policy apply to more than this MTW activity?

  • Yes

Please list all of the applicable MTW activities. (Only upload hardship policy once when said policy applies to multiple MTW activities.)

  • 3.a. - Alternative Reexamination Schedule for Households (PH);
  • 3.b. - Alternative Reexamination Schedule for Households (HCV)

Has the MTW agency modified the hardship policy since the last submission of the MTW Supplement?

  • Yes

What considerations led the MTW agency to modify the hardship policy?

  • The hardship policy was changed to include wording from the Moving to Work Operations notice

How many hardship requests have been received associated with this activity in the past year?

  • No hardship were requested in the most recent fiscal year.

Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described?

  • No

Does the MTW activity require an impact analysis?

  • Yes
  • This document is attached.

Does the impact analysis apply to more than this MTW activity?

  • Yes

Please list all of the applicable MTW activities. (Only upload impact analysis once when said impact analysis applies to multiple MTW activities.)

  • 3.a. - Alternative Reexamination Schedule for Households (PH); 3.b. - Alternative Reexamination Schedule for Households (HCV)

What is the recertification schedule?

  • Once every two years

How many interim recertifications per year may a household request?

  • 1

Please describe briefly how the MTW agency plans to address changes in family/household circumstances under the alternative reexamination schedule.

  • For households, listed above: One interim adjustment per year may be requested by the household if the household gross income has decreased 10% or more. Interim recertification for income increases will be limited to a change of $500 or more per month. Increases in income of less than $500 per month are required to be reported, but no interim will be completed.

3.b. - Alternative Reexamination Schedule for Households (HCV)

Describe the MTW activity, the MTW agency's goal(s) for the MTW activity, and, if applicable, how the MTW activity contributes to a larger initiative

  • Spartanburg Housing will implement biennial recertification for all households in which all members of the household are 60 and older or the Head of Household, Co-Head, or Spouse is disabled, even if the household members have earned income, they will be recertified only on a biennial basis. To achieve the highest level of operation efficiency, Spartanburg Housing will stagger the implementation of this activity. All certifications will be completed in 2024. Starting in January 2025 we will begin the staggering of off months making their next annual certification due in 2027. In February 2026 we will start the even-month recertification, making their next recertification due in 2028.
    • 2025 Recertification
      • Jan 2025 (Next Re-exam 2027)
      • Feb 2025 (Feb 2026)
      • Mar 2025 (Mar 2027)
      • Apr 2025 (Apr 2026)
      • May 2025 (May 2027)
      • Jun 2025 (Jun 2027)
      • Jul 2025 (Jul 2027)
      • Aug 2025 (Aug 2026)
      • Sep 2025 (Sep 2027)
      • Oct 2025 (Oct 2026)
      • Nov 2025 (Nov 2027)
      • Dec 2025 (Dec 2026)
  • For households, listed above: One interim adjustment per year may be requested by the household if the household gross income has decreased 10% or more. Interim recertification for income increases will be limited to a change of $500 or more per month. Increases in income of less than $500 per month are required to be reported, but no interim will be completed.
  • All other households and family types will recertify annually.

Which of the MTW statutory objectives does this MTW activity serve?

  • Cost effectiveness; Self-sufficiency

What are the cost implications of this MTW activity? Pick the best description of the cost implications based on what you know today.

  • Decreased expenditures

Does the MTW activity under this waiver apply to all assisted households or only to a subset or subsets of assisted households?

  • The MTW activity applies only to a subset or subsets of assisted households

Does the MTW activity apply only to new admissions, only to currently assisted households, or to both new admissions and currently assisted households?

  • New admissions and currently assisted households

Does the MTW activity apply to all family types or only to selected family types?

  • The MTW activity applies only to selected family types

Please select the family types subject to this MTW activity.

  • Elderly families; Disabled families (to the extent those families are not exempt via a reasonable accommodation)

Does the MTW activity apply to all HCV tenant-based units and properties with project-based vouchers?

  • The MTW activity applies to all tenant-based units

Based on the Fiscal Year goals listed in the activity's previous Fiscal Year's narrative, provide a description about what has been accomplished or changed during the implementation.

  • Not applicable

Does this MTW activity require a hardship policy?

  • Yes
  • This document is attached.

Does the hardship policy apply to more than this MTW activity?

  • Yes

Please list all of the applicable MTW activities. (Only upload hardship policy once when said policy applies to multiple MTW activities.)

  • 3.a. - Alternative Reexamination Schedule for Households (PH); 3.b. - Alternative Reexamination Schedule for Households (HCV)

Has the MTW agency modified the hardship policy since the last submission of the MTW Supplement?

  • Yes

What considerations led the MTW agency to modify the hardship policy?

  • The hardship policy was changed to include wording from the MTW Operations Notice

How many hardship requests have been received associated with this activity in the past year?

  • No hardship were requested in the most recent fiscal year.

Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described?

  • No

Does the MTW activity require an impact analysis?

  • Yes
  • This document is attached.

Does the impact analysis apply to more than this MTW activity?

  • Yes

Please list all of the applicable MTW activities. (Only upload impact analysis once when said impact analysis applies to multiple MTW activities.)

  • 3.a. - Alternative Reexamination Schedule for Households (PH); 3.b. - Alternative Reexamination Schedule for Households (HCV)

What is the recertification schedule?

  • Once every two years

How many interim recertification per year may a household request?

  • 1

Please describe briefly how the MTW agency plans to address changes in family/household circumstances under the alternative reexamination schedule.

  • For households, listed above: One interim adjustment per year may be requested by the household if the household gross income has decreased 10% or more. Interim recertification for income increases will be limited to a change of $500 or more per month. Increases in income of less than $500 per month are required to be reported, but no interim will be completed.

4.a. - Vacancy Loss (HCV-Tenant-based Assistance)

Describe the MTW activity, the MTW agency's goal(s) for the MTW activity, and, if applicable, how the MTW activity contributes to a larger initiative

  • Spartanburg Housing provides landlords with a maximum payment of $500 but must not exceed one month of contract rent when an HCV participant moves out and the landlord rents the unit to another HCV participant. If the landlord chooses not to rent the unit to another HCV participant, they will forfeit this payment.
  • This would apply to all HCV units and landlords. This would not apply to PBV properties or landlords.

Which of the MTW statutory objectives does this MTW activity serve?

  • Housing choice

What are the cost implications of this MTW activity? Pick the best description of the cost implications based on what you know today.

  • Increased expenditures

Does the MTW activity under this waiver apply to all assisted households or only to a subset or subsets of assisted households?

  • The MTW activity applies only to a subset or subsets of assisted households

Does the MTW activity apply only to new admissions, only to currently assisted households, or to both new admissions and currently assisted households?

  • New admissions and currently assisted households

Does the MTW activity apply to all family types or only to selected family types?

  • The MTW activity applies to all family types

Does the MTW activity apply to all HCV tenant-based units and properties with project-based vouchers?

  • The MTW activity applies to all tenant-based units

Based on the Fiscal Year goals listed in the activity's previous Fiscal Year's narrative, provide a description about what has been accomplished or changed during the implementation.

  • This activity was implemented on June 1, 2023. There was one payment in FY2023 for vacancy loss. For FY2024 as of 3/11/2024 two vacancy loss payments have been paid.
  • FY2023 total $150
  • FY2024 total as of 8/31/2024 $1,450

Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described?

  • No

Does this policy apply to certain types of units or to all units all HCV units or only certain types of units (for example, accessible units, units in a low-poverty neighborhood, or units/landlords new to the HCV program?

  • To all units

What is the maximum payment that can be made to a landlord under this policy?

  • $500

How many payments were issued under this policy in the most recently completed PHA fiscal year?

  • 1

What is the total dollar value of payments issued under this policy in the most recently completed PHA fiscal year?

  • $150

4.b. - Damage Claims (HCV-Tenant-based Assistance)

Describe the MTW activity, the MTW agency's goal(s) for the MTW activity, and, if applicable, how the MTW activity contributes to a larger initiative

  • Spartanburg Housing will provide landlords with a maximum payment of $1,250, but not to exceed the lesser of the cost of repairs or two months of contract rent for damages caused by an HCV participant. The participant's security deposit must first be used to cover damages. Given the following steps have been followed:
  1. Move-In inspection completed and signed by both the landlord and HCV participant
  2. Move-Out inspection completed and signed by both the landlord and HCV participant
  3. Itemized list of repairs and estimated cost to repair provided to Spartanburg Housing turned in within 15 days of move-out of HCV participant
  4. Established a reasonable cost of repairs.
  • The payment will be made to the landlord when the next HAP contract is executed between the owner and Spartanburg Housing.
  • This would apply to all HCV and PBV landlords

Which of the MTW statutory objectives does this MTW activity serve?

  • Housing choice

What are the cost implications of this MTW activity? Pick the best description of the cost implications based on what you know today.

  • Increased expenditures

Does the MTW activity under this waiver apply to all assisted households or only to a subset or subsets of assisted households?

  • The MTW activity applies to all assisted households

Based on the Fiscal Year goals listed in the activity's previous Fiscal Year's narrative, provide a description about what has been accomplished or changed during the implementation.

  • This activity was implemented on June 1, 2023. There was one (1) payment for damage claims in FY 2023.
  • For FY 2024 as of 8/30/2024 three (3) damage claims have been paid.

Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described?

  • No

Does this policy apply to certain types of units or to all units all HCV units or only certain types of units (for example, accessible units, units in a low-poverty neighborhood, or units/landlords new to the HCV program?

  • To all units

What is the maximum payment that can be made to a landlord under this policy?

  • $1,250 but not to exceed the lesser of the cost of repairs or two months contract rent.

How many payments were issued under this policy in the most recently completed PHA fiscal year?

  • 1

What is the total dollar value of payments issued under this policy in the most recently completed PHA fiscal year?

  • $632

4.c. - Other Landlord Incentives (HCV- Tenant-based Assistance)

Describe the MTW activity, the MTW agency's goal(s) for the MTW activity, and, if applicable, how the MTW activity contributes to a larger initiative

  • 1) Sign-On Bonus: Spartanburg Housing will provide each new landlord with a one-time $500 sign-on bonus not to exceed one month's contract rent. This bonus will be given to the new landlord after the lease-up of the first unit. This would apply to new HCV landlords only. This would not apply to PBV landlords.
  • 2) Landlord Referral Bonus: Participating landlords, who refer a new landlord to Spartanburg Housing, would receive a $100 bonus not to exceed one month's contract rent after the first unit is leased with the new landlord. This would apply to HCV landlords only. This would not apply to PBV landlords.
  • 3) Other Incentives: Spartanburg Housing will give each existing landlord a monetary award for every 5 years they have been with Spartanburg Housing. The maximum award amount is $100 for every 5 years. This would apply to HCV landlords only. This would not apply to PBV landlords.

Which of the MTW statutory objectives does this MTW activity serve?

  • Housing choice

What are the cost implications of this MTW activity? Pick the best description of the cost implications based on what you know today.

  • Increased expenditures

Does the MTW activity under this waiver apply to all assisted households or only to a subset or subsets of assisted households?

  • The MTW activity applies to all assisted households

Based on the Fiscal Year goals listed in the activity's previous Fiscal Year's narrative, provide a description about what has been accomplished or changed during the implementation.

  • FY2023
    16 Sign-On Bonus Payment -Total $8,000
    72 5-Year Tenure Bonus Payment -Total $7,200 112 10-Year Tenure Bonus Payment -Total $22,400
  • FY2024
    15 Sign-On Bonus Payment- Total $7,500

Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described?

  • No

Does this policy apply to certain types of units or to all units all HCV units or only certain types of units (for example, accessible units, units in a low-poverty neighborhood, or units/landlords new to the HCV program?

  • To all units

What is the maximum payment that can be made to a landlord under this policy?

  • $500 is the maximum for each new landlord sign-on bonus not to exceed one month's contract rent
  • $100 is the maximum for each new landlord referral bonus not to exceed one month's contract rent
  • $100 per every 5 years is the maximum payment for each landlord tenure bonus

How many payments were issued under this policy in the most recently completed PHA fiscal year?

  • 200

What is the total dollar value of payments issued under this policy in the most recently completed PHA fiscal year?

  • $37,600

5.c. - Third-Party Requirement (HCV)

Describe the MTW activity, the MTW agency's goal(s) for the MTW activity, and, if applicable, how the MTW activity contributes to a larger initiative

  • Spartanburg Housing will perform HQS inspections on PBV units it owns, manages, and/or controls. The Director of Leased Housing will randomly select a sample of Quality Control inspections (5%) that have been completed within a 60-day period.
  • PBV participants can request an interim inspection, HQS inspection standards must not be altered as found at 24 CFR 982.401. At the Department's request, Spartanburg Housing must obtain the services of a third-party entity to determine if
  • PHA units pass HQS.

Which of the MTW statutory objectives does this MTW activity serve?

  • Cost effectiveness

What are the cost implications of this MTW activity? Pick the best description of the cost implications based on what you know today.

  • Decreased expenditures

Does the MTW activity under this waiver apply to all assisted households or only to a subset or subsets of assisted households?

  • The MTW activity applies to all assisted households

Based on the Fiscal Year goals listed in the activity's previous Fiscal Year's narrative, provide a description about what has been accomplished or changed during the implementation.

  • This is an approved activity that has not been implemented.

Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described?

  • No

Please explain or upload the description of the quality assurance method:

  • The following will explain the quality assurance method:
  1. Inspections for the last 60 days will be downloaded from the Yardi system into an Excel worksheet where the number of inspections can be determined.
  2. The number of inspections will be multiplied by 5% to determine the number of inspections that will need to be performed. We will round up in all cases.
  3. We will use a random generator to select the number of inspections to select to complete based on the number needed to complete the 5% of inspections.
  4. We will send letters to the landlords and tenants to schedule the inspections
  5. Inspections will be completed and re-inspections will be scheduled if necessary
  6. Copies of the inspections will be kept in a separate file
  • No document is attached.

12.a. - Work Requirement (PH)

Describe the MTW activity, the MTW agency's goal(s) for the MTW activity, and, if applicable, how the MTW activity contributes to a larger initiative

  • Spartanburg Housing plans to institute a three-year work/education requirement under which the head of household and household members 21-55 will be required to work or attend some type of educational institution by March 1, 2026. The work requirement will be an average of 15 hours per week/per individual. Educational requirements will be determined based on the type of education.
  • Spartanburg Housing believes this goal will create self-sufficiency for all residents who are non-elderly and non-disabled ages 21-55.
  • Residents who fail to comply with the requirement will be sanctioned. The sanctions will be progressive, increasing in magnitude the longer a client is in non-compliance.

Which of the MTW statutory objectives does this MTW activity serve?

  • Self-sufficiency

What are the cost implications of this MTW activity? Pick the best description of the cost implications based on what you know today.

  • Decreased expenditures

Does the MTW activity under this waiver apply to all assisted households or only to a subset or subsets of assisted households?

  • The MTW activity applies only to a subset or subsets of assisted households

Does the MTW activity apply only to new admissions, only to currently assisted households, or to both new admissions and currently assisted households?

  • New admissions and currently assisted households

Does the MTW activity apply to all family types or only to selected family types?

  • The MTW activity applies only to selected family types

Please select the family types subject to this MTW activity.

  • Non-elderly, non-disabled families

Does the MTW activity apply to all public housing developments?

  • The MTW activity applies to all developments

Based on the Fiscal Year goals listed in the activity's previous Fiscal Year's narrative, provide a description about what has been accomplished or changed during the implementation.

  • Not applicable

Does this MTW activity require a hardship policy?

  • Yes
  • This document is attached.

Does the hardship policy apply to more than this MTW activity?

  • Yes

Please list all of the applicable MTW activities. (Only upload hardship policy once when said policy applies to multiple MTW activities.)

  • 3.a. - Alternative Reexamination Schedule for Households (PH); 3.b. - Alternative Reexamination Schedule for Households (HCV)

Has the MTW agency modified the hardship policy since the last submission of the MTW Supplement?

  • Yes

What considerations led the MTW agency to modify the hardship policy?

  • The wording was changed to include wording from the Moving to Work Operations Notice and add wording about the Self-Sufficiency/Work Requirement hardship policy.

How many hardship requests have been received associated with this activity in the past year?

  • No hardship were requested in the most recent fiscal year.

Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described?

  • No

Does the MTW activity require an impact analysis?

  • Yes
  • This document is attached.

Does the impact analysis apply to more than this MTW activity?

  • No

Does the work requirement MTW activity exempt any type of household or individual other than those required to be excluded through the MTW Operations Notice or those excluded as a reasonable accommodation?

  • Yes

Please describe the conditions for exemption.

  • Those individuals exempt from the Community Service Requirement
  • Individuals who are the primary caretaker for a child under 6 years of age or who are pregnant are also exempt
  • Elderly and Disabled Families

What counts as 'work" under this the work requirement MTW activity?

  • Job Training Course
  • Part-time employment of at least 15 hours per week per individual
  • Part-time student in college course

How will the MTW agency monitor compliance with the work requirement MTW activity?

  • Spartanburg Housing will work with the resident to monitor compliance with the work/education requirement. We will create a tracking sheet for the families that are expected to have to comply with the work/education requirement.

What supportive services are offered to support households to comply with the work requirement?

  • Spartanburg Housing will pursue partnerships with community organizations to offer support services to the affected households.

How does the agency address noncompliance with the work requirement policy?

  • The families that are non-compliant will have several levels of sanctions including counseling, a loss of subsidy for up to 3 months and finally 100% loss of subsidy.

How many households are currently subject to the policy?

  • 170

How many households in the most recently completed PHA fiscal year were sanctioned for non-compliance with the work requirement?

  • 0

D. Safe Harbor Waivers.

D.1 Will the MTW agency submit request for approval of a Safe Harbor Waiver this year?

  • No Safe Harbor Waivers are being requested.

E. Agency-Specific Waiver(s).

E.1 Agency-Specific Waiver(s) for HUD Approval:

  • The MTW demonstration program is intended to foster innovation and HUD encourages MTW agencies, in consultation with their residents and stakeholders, to be creative in their approach to solving affordable housing issues facing their local communities. For this reason, flexibilities beyond those provided for in Appendix I may be needed. Agency-Specific Waivers may be requested if an MTW agency wishes to implement additional activities, or waive a statutory and/or regulatory requirement not included in Appendix I.
  • In order to pursue an Agency-Specific Waiver, an MTW agency must include an Agency-Specific Waiver request, an impact analysis, and a hardship policy (as applicable), and respond to all of the mandatory core questions as applicable.
  • For each Agency-Specific Waiver(s) request, please upload supporting documentation, that includes: a) a full description of the activity, including what the agency is proposing to waive (i.e., statute, regulation, and/or Operations Notice), b) how the initiative achieves one or more of the 3 MTW statutory objectives, c) a description of which population groups and household types that will be impacted by this activity, d) any cost implications associated with the activity, e) an implementation timeline for the initiative, f) an impact analysis, g) a description of the hardship policy for the initiative, and h) a copy of all comments received at the public hearing along with the MTW agency's description of how the comments were considered, as a required attachment to the MTW Supplement.

Will the MTW agency submit a request for approval of an Agency-Specific Waiver this year?

  • No

E.2 Agency-Specific Waiver(s) for which HUD Approval has been Received:

Does the MTW agency have any approved Agency-Specific Waivers?

  • No

F. Public Housing Operating Subsidy Grant Reporting.

F.1 Total Public Housing Operating subsidy amount authorized, disbursed by 9/30, remaining, and deadline for disbursement, by Federal Fiscal Year for each year the PHA is designated an MTW agency.

  • Federal Fiscal Year (FFY): 2022 
    • Total Operating Subsidy Authorized Amount: $1,777,715 
    • How Much PHA Disbursed by the 9/30 Reporting Period: $1,326,973 
    • Remaining Not Yet Disbursed: $0 
    • Deadline: 2022-12-31
  • Federal Fiscal Year (FFY): 2023 
    • Total Operating Subsidy Authorized Amount: $1,934,803 
    • How Much PHA Disbursed by the 9/30 Reporting Period: $1,934,803 
    • Remaining Not Yet Disbursed: $0 
    • Deadline: 2023-12-31
  • Federal Fiscal Year (FFY): 2024 
    • Total Operating Subsidy Authorized Amount: $1,878,380 
    • How Much PHA Disbursed by the 9/30 Reporting Period: $1,116,257 
    • Remaining Not Yet Disbursed: $762,123 
    • Deadline: 2024-12-31
  • Federal Fiscal Year (FFY): 2025 
    • Total Operating Subsidy Authorized Amount: $0
    • How Much PHA Disbursed by the 9/30 Reporting Period: $0
    • Remaining Not Yet Disbursed: $0
    • Deadline: 

G. MTW Statutory Requirements.

G.1 75% Very Low Income - Local, Non-Traditional.

HUD will verify compliance with the statutory requirement that at least 75% of the households assisted by the MTW agency are very low-income for MTW public housing units and MTW HCVs through HUD systems. The MTW PHA must provide data for the actual families housed upon admission during the PHA's most recently completed Fiscal Year for its Local, Non-Traditional program households.

  • Income Level: 80%-50% Area Median Income
    • Number of Local, Non-Traditional Households Admitted in the Fiscal Year*
  • Income Level: 49%-30% Area Median Income
    • Number of Local, Non-Traditional Households Admitted in the Fiscal Year*
  • Income Level: Below 30% Area Median Income
    • Number of Local, Non-Traditional Households Admitted in the Fiscal Year*
      • Total Local, Non-Traditional Households 0

*Local, non-traditional income data must be provided in the MTW Supplement form until such time that it can be submitted in IMS-PIC or other HUD system.

G.2 Establishing Reasonable Rent Policy.

G.3 Substantially the Same (STS) - Local, Non-Traditional.

  • The total number of unit months that families were housed in a local, non-traditional rental subsidy for the prior full calendar year.
    • # of unit months
  • The total number of unit months that families were housed in a local, non-traditional housing development program for the prior full calendar year.
    • # of unit months

Number of units developed under the local, non-traditional housing development activity that were available for occupancy during the prior full calendar year:

  • PROPERTY NAME/ ADDRESS
  • 0/1 BR
  • 2 BR
  • 3 BR
  • 4 BR
  • 5 BR
  • 6+ BR
  • TOTAL UNITS
  • POPULATION TYPE*
  • if 'Population Type' is Other
  • # of Section 504 Accessible (Mobility)**
  • # of Section 504 Accessible (Hearing/ Vision)
  • Was this Property Made Available for Initial Occupancy during the Prior Full Calendar Year?
  • What was the Total Amount of MTW Funds Invested into the Property?

G.4 Comparable Mix (by Family Size) - Local, Non-Traditional.

To demonstrate compliance with the statutory requirement to continue serving a 'comparable mix" of families by family size to that which would have been served without MTW, the MTW agency will provide the number of families occupying local, non-traditional units by household size for the most recently completed Fiscal Year in the provided table.

  • Family Size: 1 Person
  • Occupied Number of Local, Non-Traditional units by Household Size
  • Family Size: 2 Person
  • Occupied Number of Local, Non-Traditional units by Household Size
  • Family Size: 3 Person
  • Occupied Number of Local, Non-Traditional units by Household Size
  • Family Size: 4 Person
  • Occupied Number of Local, Non-Traditional units by Household Size
  • Family Size: 5 Person
  • Occupied Number of Local, Non-Traditional units by Household Size
  • Family Size: 6+ Person
  • Occupied Number of Local, Non-Traditional units by Household Size
  • Totals 0

H. Public Comment

  • Attached you will find a copy of all of the comments received and a description of how the agency analyzed the comments, as well as any decisions made based on those comments.

I. Evaluations.

  • No known evaluations.

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