Neighborhood Homes update from Dallas Housing Authority/CPSH Response

From DHA (CPSH response below

Ms. Robin LeoGrande,
My team and I appreciate the opportunity to speak with you yesterday to discuss your concerns about the Dallas Housing Authority’s (DHA) Request for Proposals (RFP) seeking suitable project based rental housing opportunities for persons with intellectual or developmental disabilities.  Due to existing circumstances at DHA including a change in leadership and change to the agencies operational software and other competing priorities, DHA has not concluded its process or awarded contracts related to the subject RFP. 
Current DHA leadership has called upon the Housing Authority’s funding agency, the U.S. Department of Housing and Urban Development, to address an area of concern with the program implementation strategy.  We believe that there may exist in the program strategy a specific violation of HUD regulatory requirements that both the DHA and program participants will need to avoid.  For example; existing HUD regulations governing the Housing Choice Voucher program prohibit participating landlords from renting to relatives. DHA understands that some prospective applicants may have intention of renting their awarded project based housing unit to a relative.  DHA’s new leadership, aware of HUD’s longstanding position prohibiting renting assisted units to close relatives, is seeking confirmation from its funding agency that its anticipated remedy to this concern is acceptable to HUD.  In the spirit of clear communication DHA will need to notify proposers in advance of an award of contract if HUD rejects DHA’s strategy and prohibits proposers from renting their project based rental units to relatives.
Regrettably, as a result of DHA’s competing priorities and time required to secure a response from HUD, DHA has not concluded its due diligence and awarded contracts related to this RFP as planned.  It is our sincere intention to conclude all necessary and appropriate due diligence as soon as possible.  DHA will notify all respondents that it has revised its RFP processing schedule anticipating that the process will be concluded by or before March 1, 2017.
Thank you for bringing this matter to my attention.  DHA appreciates your advocacy on behalf of persons with intellectual and developmental disabilities.
Confidentiality Notice: The information contained in this email and any attachments to it may be legally privileged and include confidential information intended only for the recipient(s) identified above. If you are not one of those intended recipients, you are hereby notified that any dissemination, distribution or copying of this email or its attachments is strictly prohibited. If you have received this email in error, please notify the sender or The Housing Authority of the City of Dallas, Texas of that fact by return email, and permanently delete and destroy the email and any attachments to it immediately. Please do not retain, copy or use this email or its attachments for any purpose, nor disclose all or any part of its contents to any other person. Thank you.

Response From CPSH

Mr. Broussard,
Thank you for this email.  I will share it.

Regarding homeowners having intention of renting their awarded project based housing unit to a relative, this issue was previously addressed by MaryAnn.  I provided the attached regulation to Brooke last year. (In the newsletter, no attachment)

Generally, a PHA must not approve an owner under Section 8 if he or she is a relative of a tenant. 24 C.F.R. § 982.306(d). However, the PHA may approve such an owner if it would be a reasonable accommodation for the family member, who is a person with a disability.

I have saved all my research and documentation over the years that DHA and CPSH have worked together to promote more housing options for adults with IDD.  Please let me know if you need information. If I have it, I would be glad to share it.

If there are other issues regarding regulations or laws that are causing concerns about the implementation of PBVs I respectfully request we discuss them as soon as you are aware of them.  It is to our mutual benefit that this process go smoothly.

Thank you for your attention to this matter.  I look forward to continuing our relationship to help this underserved population.

Best regards,  
Robin LeoGrande, President

end of correspondence