This document summarizes requirements for public housing authorities regarding civil rights and compliance programs from the U.S. Department of Housing and Urban Development (HUD). It outlines four basic civil rights requirements including prohibiting discrimination and providing reasonable accommodations. HUD conducts comprehensive compliance reviews to ensure authorities follow laws including the Fair Housing Act. The reviews examine documents and policies through on-site assessments. Outcomes may include letters of findings or voluntary compliance agreements to address any issues found. Public housing authorities must also affirmatively further fair housing and complete an analysis of impediments to fair housing in their jurisdiction.
If you say the word “discovery” to a litigator, the reaction may not be kind. Discovery—the exchange of relevant information, usually in the form of documents or oral depositions, takes up the majority of a litigator’s time and costs clients the most money. This episode begins with a summary of the rules governing discovery. In particular, we discuss the new federal rules governing the preservation and discovery of electronic data and information, and the new concept of “proportionality” in discovery. We also discuss the practicalities of discovery: budgeting, tactics, and common opportunities and pitfalls. This hour demystifies a mystifying process, and to provide listeners with what they need to know to not get tripped up in litigation. At the very least, you will understand why the acronym “ESI” causes our panel to wince.
Part of the webinar series: NEWBIE LITIGATOR SCHOOL- 101 PART I 2022
See more at https://www.financialpoise.com/webinars/
Massachusetts CDBG Five-Year Plan Comments FELDMAN
The State has published its draft of a five-year Comprehensive Plan to use HUD funds, over 52 million dollars, for 2010-2014. (Actually the beginning of the program year began in Fall, 2009).
This disAbility advocate is reminding the State's Department of Housing and Community Development (DHCD) to administer, program and implement these funds so that they are inclusive of individuals and families with disAbilities across the State.
The essential question is: Are these programs allowing individuals living with disAbilities equitable opportunities to participate in any role they are qualified for, and wish to engage in?
Regulatory requirements for improving access to housing are powerful tools for removing barriers to housing choice and increasing housing opportunities. Local, state and federal laws can help you address unreasonable barriers put in place by neighbors or advocate for inclusive housing through planning and land use processes. The new affirmatively furthering fair housing rules at US Department of Housing and Urban Development will shape housing options for years to come. This session will provide an overview of applicable regulatory tools and practical discussion of how to apply them
Margaret Solle Salazar, Portland Field Office Director, US Dept of Housing and Urban Development
Pam Phan, 1000 Friends of Oregon and Anti-Displacement PDX
Martha McLennan, Executive Director, Northwest Housing Alternatives
This interactive session will include a brief discussion of the HMIS data standards revisions and will allow participants to ask questions about these revisions as well as changes due to the American Reinvestment and Recovery Act, changes to the Universal and Program-Specific data elements, and other topics such as privacy, security, and data quality.
Communities across the country have submitted questions to the HUD Homelessness Prevention and Rapid Re-Housing Program (HPRP) Virtual Help Desk. Now you can meet the experts! Program experts will offer their insights, discuss frequently asked questions, and field queries from participants.
Initial Findings from Community Survey on Housing NeedsMaileen Hamto
Presented by RNR Consulting at Portland Housing Bureau Community Forum (Portland, Oregon). Illustrates housing needs and initial findings from comprehensive community survey.
If you say the word “discovery” to a litigator, the reaction may not be kind. Discovery—the exchange of relevant information, usually in the form of documents or oral depositions, takes up the majority of a litigator’s time and costs clients the most money. This episode begins with a summary of the rules governing discovery. In particular, we discuss the new federal rules governing the preservation and discovery of electronic data and information, and the new concept of “proportionality” in discovery. We also discuss the practicalities of discovery: budgeting, tactics, and common opportunities and pitfalls. This hour demystifies a mystifying process, and to provide listeners with what they need to know to not get tripped up in litigation. At the very least, you will understand why the acronym “ESI” causes our panel to wince.
Part of the webinar series: NEWBIE LITIGATOR SCHOOL- 101 PART I 2022
See more at https://www.financialpoise.com/webinars/
Massachusetts CDBG Five-Year Plan Comments FELDMAN
The State has published its draft of a five-year Comprehensive Plan to use HUD funds, over 52 million dollars, for 2010-2014. (Actually the beginning of the program year began in Fall, 2009).
This disAbility advocate is reminding the State's Department of Housing and Community Development (DHCD) to administer, program and implement these funds so that they are inclusive of individuals and families with disAbilities across the State.
The essential question is: Are these programs allowing individuals living with disAbilities equitable opportunities to participate in any role they are qualified for, and wish to engage in?
Regulatory requirements for improving access to housing are powerful tools for removing barriers to housing choice and increasing housing opportunities. Local, state and federal laws can help you address unreasonable barriers put in place by neighbors or advocate for inclusive housing through planning and land use processes. The new affirmatively furthering fair housing rules at US Department of Housing and Urban Development will shape housing options for years to come. This session will provide an overview of applicable regulatory tools and practical discussion of how to apply them
Margaret Solle Salazar, Portland Field Office Director, US Dept of Housing and Urban Development
Pam Phan, 1000 Friends of Oregon and Anti-Displacement PDX
Martha McLennan, Executive Director, Northwest Housing Alternatives
This interactive session will include a brief discussion of the HMIS data standards revisions and will allow participants to ask questions about these revisions as well as changes due to the American Reinvestment and Recovery Act, changes to the Universal and Program-Specific data elements, and other topics such as privacy, security, and data quality.
Communities across the country have submitted questions to the HUD Homelessness Prevention and Rapid Re-Housing Program (HPRP) Virtual Help Desk. Now you can meet the experts! Program experts will offer their insights, discuss frequently asked questions, and field queries from participants.
Initial Findings from Community Survey on Housing NeedsMaileen Hamto
Presented by RNR Consulting at Portland Housing Bureau Community Forum (Portland, Oregon). Illustrates housing needs and initial findings from comprehensive community survey.
2. BASIC HUD CIVIL RIGHTS PROGRAM
REQUIREMENTS
1. Do not discriminate on the basis of race,
color, religion, sex, national origin,
disability, or familial status (children in
the household)
2. Provide equal opportunity to all eligible
applicants
2
3. BASIC HUD CIVIL RIGHTS PROGRAM
REQUIREMENTS
3. Provide a reasonable accommodation
for the needs of persons with disabilities
4. Administer programs “in a manner to
affirmatively further fair housing”
3
4. WHAT IS A COMPLIANCE REVIEW?
Comprehensive examination of Recipients’
operations under a variety of legal authorities, to
ensure that they are complying with the
requirements
of those laws
4
5. THE LEGAL AUTHORITIES UNDER
WHICH WE REVIEW:
Fair Housing Act
Title VI of the Civil Rights Act of 1964
Section 504 of the Rehabilitation Act of
1973
Americans with Disabilities Act
5
6. COMPLIANCE ASSESSMENT
PIH: (1) number of complaints against the PHA in the
recent past; (2) PHA Plan reviews – specifically the AFFH
self-analysis required by 24 CFR 903.7(o); (4) analysis of
PICS data to determine if suspect racial concentrations
exist; (5) discussion with PIH staff
Key contacts:
Executive Director, Section 504 Coordinator, Section 8
program chief, Public Housing program chief, head of the
maintenance department, tenant council presidents at
various properties (if applicable)
6
7. BASIC STEPS FOR COMPLIANCE REVIEW
Notification to PHA and request for data and
documents
Off-site preliminary document and data review
On-site review
7
8. REVIEW RELEVANT DOCUMENTS
Reasonable Accommodation Policy
Grievance Policy/Procedures
Tenant policies/rules.
Waiting List
Employment and hiring policies
Documents associated with reasonable accommodation
requests from tenants and employees for last three years
Racial/ethnic data of employees and tenants.
8
10. SECTION 504 VIOLATIONS
Inaccessible dwelling units and common
areas
Lack of reasonable accommodation policy
and procedures
Failure or delay in making reasonable
accommodation
10
11. Fair Housing Act 42 U.S.C.
3608(d) and (e)(5): HUD & other
federal agencies must administer
programs and activities relating to
housing and urban development
“in a manner affirmatively to
further” fair housing policies.
11
12. HUD CIVIL RIGHTS REGULATIONS
A Public Housing Authority is required to provide a certification
of its AFFH compliance through its Civil Rights certification
with its Annual Plan (PHA) submission.
Review AI to Fair Housing Choice Technical Assistance Memo
for Public Housing
Necessary Action by PHA
Examine programs or proposed programs
Identifies any impediments to fair housing within program
areas
Address impediments in a reasonable time frame
Maintain records reflecting these analysis and actions
12
13. TAKE ACTION TO FIX THE PROBLEMS
PHA should
complete
a comprehensive
AI based upon its 5
year PHA plan cycle.
Update as needed in
your annual PHA
plan. 13
14. OVERCOME IMPEDIMENTS
Address each identified impediment
Set goals with measurable results
Determine time period for completion
Not everything can be accomplished in one
year – set a schedule & ID milestones
Identify resources
14
15. ON THE HUD WEB SITE:
Promoting Fair Housing web page:
http://www.hud.gov/offices/fheo/promotingf
h.cfm
Planning Guide:
http://www.hud.gov/utilities/intercept.cfm?h
ttp://www.hud.gov/offices/fheo/images/fhp
g.pdf
15
16. CONTACT INFORMATION
Barbara Delaney
Philadelphia Center Director
U.S. Department of Housing and Urban
Development
Office of Fair Housing and Equal Opportunity
100 Penn Square East
Philadelphia, Pennsylvania
Telephone: 215-861-7637
16