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From: Susan Hegel
email: mailto:shegel@gbls.org
link: http://
date: 12/14/0 13:13
Date: 12/21/00
Time: 1:11:20 PM
Remote Name: 207.251.188.199
Our office is representing a RAB in its negotiations with a local housing authority with a 4/1 -3/31 fiscal year. The LHA seems prepared to adopt the RAB's proposed community service policy but has a concern about its effective date. As drafted, the policy would be effective as of 4/1/01, but the 8 hours/month requirement for an individual tenant would start at that tenant's next annual recertification after 4/1/01 -- in other words, there would be one year phase-in. This LHA does not recertify everyone as of the same month, but rather uses the anniversary date of move-in as the annual recert. date. The regulations and FR comments do not specifically address whether this is or is not permissible.
Has anyone proposed or seen a community service requirement which applies as of a tenant's next annual recertification date, which will vary from tenant to tenant? Has anyone sought and/or obtained guidance from HUD on this issue? Thanks.
P.S. If anyone wants an email copy of the proposed policy as a model, let me know. It is largely based on MacMcCreight's work with Boston Housing Authority, but has a fair number of changes favorable to tenants.