Moving To Work (MTW) FY25 Moving to Work Supplement FY27 MTW Supplement FY28 MTW Supplement Habitat for Humanity Partnership Move to Work Notices Moving to Work Collaborative Fact Sheet Moving to Work Impact

FY28 MTW Supplement

To view the Housing Authority of New Smyrna Beach's complete Moving to Work Supplement for Fiscal Year 2028, please click HERE.

The Housing Authority of the City of New Smyrna Beach
Moving to Work Supplement
Fiscal Year 2028

Table of Contents

A. PHA Information
B. Narrative
C. MTW Waivers and Associated Activities

ACTIVITY 1 1.e., 1.f. Minimum Rent (PH & HCV)
ACTIVITY 2 1.i., 1.j. Alternative Utility Allowance (Public Housing & HCV)
ACTIVITY 3 1.r., 1.s. Elimination of Deductions (Public Housing & HCV)
ACTIVITY 4 1.m., 1.n. Utility Reimbursements (Public Housing & HCV)
ACTIVITY 5 1.v., 1.w. Alternative Income Inclusions/Exclusions (Public Housing & HCV)
ACTIVITY 6 2.b. Payment Standards -Fair Market Rents (HCV)
ACTIVITY 7 3.a., 3.b. Alternative Recertification Schedule For Households (Public Housing & HCV)
ACTIVITY 8 3.c., 3.d. Self-Certification of Assets (Public Housing & HCV)
ACTIVITY 9 5.d. Alternative Inspection Schedule (HCV)
ACTIVITY 10 9.b. Increase PBV Project Cap (HCV)
ACTIVITY 11 12.a., 12.b. Work Requirement (Public Housing & HCV)
ACTIVITY 12 10.c. FSS Alternative Family Selection Procedures (PH & HCV)
ACTIVITY 13 10.d. FSS Modify or Eliminate the Contract of Participation (PH & HCV)
ACTIVITY 14 7.a., 7.b. Term Limits (PH & HCV)

D. Safe Harbor Waivers
E. Agency-Specific Waivers
F. Public Housing Operating Subsidy Grant Reporting
G. MTW Statutory Requirements
H. Public Comments
I. Evaluations
J. MTW Certifications of Compliance
APPENDICES
Hardship Policy

A. PHA Infoormation
A.1
PHA Name: New Smyrna Beach Housing Authority
PHA Code: FL022
MTW Supplement for PHA Fiscal Year Beginning: 04/01/2027
PHA Program Type: Combined
MTW Cohort Number: 1
MTW Supplement Submission Type: Annual Submission
B. Narrative
B.1
The New Smyrna Beach Housing Authority (NSBHA), established in 1950, is located in New Smyrna Beach, Florida. The NSBHA administers both the Public Housing and Housing Choice Voucher (HCV) programs as well as affordable housing options to all eligible households regardless of race, color, religion, sex, physical or mental handicap, familial status, national origin, or other protected class. The NSBHA is committed to providing quality, affordable housing, that enhances the lives of its residents and promotes their independence. The overall vision for the NSBHA's Moving to Work (MTW) program is to create a quality housing model that transforms families from poverty to prosperity while sustaining financial viability of the authority through the implementation of efficient business processes. Additionally, the NSBHA will develop and implement a comprehensive, integrated, and coordinated service delivery architype that combines housing, coaching and mentoring, life skills and empowerment, education, and workforce development. Lastly, the NSBHA will reposition its public housing portfolio through demolition and new construction, which will include implementing initiatives that will provide families with more housing choices, employment, and educational centers.

NSBHA has created 80 new units of affordable senior housing through demolition and disposition of 34 public housing units using LIHTC in 2024. This property has 70 units of Project-Based Vouchers.

NSBHA has 541 Housing Choice Vouchers and 91 public housing units. Of the 91 public housing units 40 are under natural disaster and 40 are scheduled for a demolition/disposition once funding is received. The remaining 11 units are planned for rehabilitation under the public housing program.

The agency has implemented the mandatory 15 hours a week working requirement along with the Family Self-Sufficiency (FSS) program in 2025. Since 2021, the FSS program has increased to over 88 participants and 70 more families are now employed. Thirteen (13) families have graduated from the FSS program in five years; six (6) of them have entered homeownership and have left the low-income housing program. NSBHA's goals are to continue to increase the number of non-elderly, non-disabled families in the FSS program and into the working community using the MTW model and help them overcome their barriers.

By implementing the nine-year FSS contract along with the nine-year term limit for housing simultaneously, NSBHA aspires to make families self-sufficient by the time their FSS contracts are complete allowing them to utilize their escrow balances to exit the program.
C. MTW Waivers and Associated Activities
Activitiy 1 1.e, 1.f. Minimum Rent (PH B&HCV)
Core Questions
1. Fiscal Year Introduced: 2023
2. Fiscal Year Approved: 2023
3. Status: Implemented
4. Narrative: The NSBA will implement a minimum rent for eligible non-elderly and non-disabled households to encourage self-sufficiency. The minimum rent for these households will increase from $50 to $130.
5. MTW Statutory Objectives: Cost effectiveness, Self-sufficiency
6: Cost Implications: Increased revenue, Decreased Expenditures
7. Policy by Household Status/Family Types/Sites: The MTW activity applies only to subset or subsets of assisted households
8. Household Status: New admissions and currently assisted households
9. Family Types: The MTW activity only applies to selected family types: Non-elderly, non-disabled families
10. Location: For PH Activities: The MTW activity applies to all developments; For HCV Activities: The MTW activity applies to all tenant-based unites, The MTW activity applies to properties with project-based vouchers
11. Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described? No
12. Does this MTW activity require a hardship policy? Yes
13. Does the hardship policy apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities.
Yes
1. Minimum Rent
2. Payment Standards - Fair Market Rents
3. Alternative Recertification Schedule For Households
4. Elimination of Deductions
5. Work Requirement
6. FSS Alternative Family Selection Procedures
7. FSS Modify or Eliminate the Contract of Participation
8. Term Limits
14. Has the MTW agency modified the hardship policy since the last submission of the MTW Supplement? No.
15. How many hardship requests have been received associated with this activity in the most recently completed PHA fiscal year? Zero
16. Does the MTW activity require an impact analysis? Yes.
17. Does the impact analysis apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
18. 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.
Nineteen able-bodied families were paying $0 in rent prior to this activity. With the savings from the elimination of utility allowance payments coupled with the increase in minimum rent, the NSBHA has received over $171,059 in additional income since the inception of these activities.
19. Please provide an explanation as to why the activity was discontinued or will be discontinued. N/A

Custom Questions
1. How much is the minimum rent or minimum Total Tenant Payment (TTP)? $130
Impact Analysis
1. Impact on the agency's finances (e.g., how much will the activity cost, any change in the agency's per family contribution

Public Housing
There are currently nine (9) able-bodied families in the public housing program whose income-based rent is less than the minimum rent of $50. It is anticipated that the increase in the minimum rent to $130 will increase the amount of monthly tenant rent collected by at least a total of $1,004 or $12,048 annually.
Housing Choice Voucher
There are currently approximately 26 able-bodied families in the voucher program whose income-based rent is at or less than the minimum rent of $50. It is anticipated that the increase in the minimum rent to $130 will decrease the amount of monthly housing assistance payments (HAP) by at least a total of $3,008 or $36,096 annually.
2. Impact on affordability of housing costs for affected families (e.g., any change in how much affected families will pay towards their housing costs)
Public Housing
Program rules dictate a family must pay the higher of the tenant-based rent or the minimum rent. Currently there are nine public housing families that pay less than the minimum rent of $50.
It is anticipated the implementation of an increased minimum rent will raise the tenant rent paid by affected families in the public housing program by an average of 1,344%.
Housing Choice Voucher
Program rules dictate a family must pay the higher of 30% of adjusted income or 10% of gross income and never less than the minimum rent. Currently there are 26 HCV families that pay the minimum rent of $50 or less.
It is anticipated the implementation of an increased minimum rent will raise the tenant rent paid by affected families in the HCV Program by an average of 826%.
3. Impact on the agency's waitlist(s) (e.g., any change in the amount of time families are on the waitlist)
This activity will not affect the waiting list.
4. Impact on the agency's termination rate of families (e.g., any change in the rate at which families non-voluntarily lose assistance from the agency)
This activity will not affect the termination rate of families.
5. Impact on the agency's current occupancy level in public housing and utilization rate in the HCV program
This activity will not affect the agency's current occupancy level in public housing or utilization rate in the HCV program.

6. Impact on meeting the MTW statutory goals of cost effectiveness, self-sufficiency, and/or housing choice
MTW Statutory Objective - Cost Effectiveness
This activity will increase the cost effectiveness of both the Public Housing and HVC Programs. The amount of tenant rent collected in the public housing program will increase and the amount of HAP paid under the HCV program will decrease. These funds will be available to fund self-sufficiency activities, preserve existing affordable housing assets, and acquire new affordable housing assets.
MTW Statutory Objective - Self Sufficiency
This activity will provide incentives for families to work, decrease the incentive to voluntarily make decisions that would reduce household income, and reduce client dependance on the subsidy safety net.
7. Impact on the agency's ability to meet the MTW statutory requirements
This activity will enable NSBHA to meet both the statutory objectives of Cost Effectiveness and Self-Sufficiency.
8. Impact on the rate of hardship requests and the number granted and denied as a result of this activity
It is anticipated that the rate of hardship requests will increase regarding minimum rent activities for both the public housing and HCV Programs, and it is expected that the majority of initial minimum rent waiver requests will be approved.
9. Across the other factors above, the impact on protected classes (and any associated disparate impact)
This activity is implemented based on income reviews in which protected class is not a factor. Therefore, there is no anticipated impact on protected classes.
Activity 2 1.i., 1.j. Alternative Utility Allowance (Public Housing & HCV)

Core Questions
1. Fiscal Year Introduced: 2023
2. Fiscal Year Approved: 2023
3. Status: Implemented
4. Narrative: The NSBHA will streamline its recertifications by employing a standard utility allowance for its public housing and HCV households. This act will reduce staff hours, allowing staff to focus on other matters. Additionally, it will allow the household rent/portion to increase helping households to realize a more market rate rent.
5. MTW Statutory Objectives: Cost effectiveness
6. Cost Implications: Increased revenue, Decreased expenditures
7. Policy by Household Status/Family Types/Sites: The MTW activity applies to all assisted households
8. Household Status: New admissions and currently assisted households
9. Family Types: The MTW activity applies to all family types
10. Location
For PH Activities: The MTW activity applies to all developments
For HCV Activities:
1. The MTW activity applies to all tenant-based units
2. The MTW activity applies to all properties with project-based vouchers
11. Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described? No
12. Does this MTW activity require a hardship policy? No
13. Does the hardship policy apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
14. Has the MTW agency modified the hardship policy since the last submission of the MTW Supplement? No
15. How many hardship requests have been received associated with this activity in the most recently completed PHA fiscal year? Zero
16. Does the MTW activity require an impact analysis? No
17. Does the impact analysis apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No

18. 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 has reduced the staff time in processing tenant exams.
19. Please provide an explanation as to why the activity was discontinued or will be discontinued. N/A
Custom Questions

1. Please describe the alternative method of calculating the utility allowances. Please explain how the method of calculating utility allowances is different from the standard method and what objective the MTW agency aims to achieve by using this alternative method.

Utility allowances, using the standard method, are the deduction of individual utilities based on bedroom size and dwelling type from a household's Total Tenant Payment (TTP). The NSBHA will make a standardized utility allowance by averaging every utility type and then adding those averages together based on bedroom size and dwelling type (multi-family and single-family). This will result in a single utility allowance amount, based on bedroom size and dwelling type, that will be deducted from a household's TTP. The NSBHA will have two standard utility allowance schedules based on bedroom size and dwelling type for HCV and one standard utility allowance schedule based on bedroom size for public housing. This new practice will reduce the administrative burden on the NSBHA's staff during recertifications.
Activity 3 1.r., 1.s. Elimination of Deductions (Public Housing & HCV)
Core Questions
1. Fiscal Year Introduced: 2023

2. Fiscal Year Approved: 2023

3. Status: Implemented
4. Narrative: The NSBHA will streamline its recertifications by eliminating deductions and the standard of rent based on adjusted income for all able-bodied public housing and HCV households. The total tenant payment (TTP) will be calculated based on gross income, and eligible households will pay at least the minimum rent of $130. This activity will increase the household rent/rental portion, which will in turn decrease HAP and increase revenue for the NSBHA. These realized funds will be used to increase supportive services for families.
5. MTW Statutory Objectives: Cost effectiveness
6. Cost Implications: Increased revenue, Decreased expenditures
7. Policy by Household Status/Family Types/Sites: The MTW activity applies only to a subset or subsets of assisted households
8. Household Status: New admissions and currently assisted households
9. Family Types: The MTW activity applies only to selected family types: Non-elderly, non-disabled families
10. Location
For PH Activities: The MTW activity applies to all developments

For HCV Activities:
1. The MTW activity applies to all tenant-based units
2. The MTW activity applies to all properties with project-based vouchers
11. Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described? No
12. Does this MTW activity require a hardship policy? Yes
13. Does the hardship policy apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. Yes
1. Minimum Rent
2. Elimination of Deductions
3. Payment Standards - Fair Market Rents
4. Alternative Reexamination Schedule for Households
5. Work Requirement
6. FSS Alternative Family Selection Procedures
7. FSS Modify or Eliminate the Contract of Participation
8. Term Limits
14. Has the MTW agency modified the hardship policy since the last submission of the MTW Supplement? No
15. How many hardship requests have been received associated with this activity in the most recently completed PHA fiscal year? Zero
16. Does the MTW activity require an impact analysis? Yes
17. Does the impact analysis apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
18. 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 has reduced the staff time in processing tenant exams.
19. Please provide an explanation as to why the activity was discontinued or will be discontinued. N/A
Custom Questions
1. Which deduction(s)will be eliminated, modified, or added?
Dependent allowance, Unreimbursed childcare costs, Disability assistance (non-head, spouse, or co-head)
Impact Analysis
1. Impact on the agency's finances (e.g., how much will the activity cost, any change in the agency's per family contribution
The NSBHA is eliminating standardized income deductions for all non-elderly, non-disabled families in the public housing and HCV programs. In addition, the NSBHA is increasing the minimum rent from $50 to $130 and implementing a standard utility allowance based on bedroom size and dwelling type. Eliminating $16,835 of annual income deductions will be evident through an increase in revenue and a decrease in HAP for the NSBHA.

2. Impact on affordability of housing costs for affected families (e.g., any change in how much affected families will pay towards their housing costs)
This activity will be employed in tandem with a minimum rent. Total tenant payment (TTP) will be calculated based on gross rent, and families will pay at least the minimum rent of $130. At present, this activity will only affect five families, who all receive a childcare deduction. These families will see an increase in their rental amount/rental portion; however, many able-bodied families may see an increase in their rental amount/rental portion due to the introduction of the minimum rent.
3. Impact on the agency's waitlist(s) (e.g., any change in the amount of time families are on the waitlist)
This activity will not affect the waiting list.
4. Impact on the agency's termination rate of families (e.g., any change in the rate at which families non-voluntarily lose assistance from the agency)
This activity will not affect the termination rate of families.
5. Impact on the agency's current occupancy level in public housing and utilization rate in the HCV program
This activity will not affect the agency's current occupancy level in public housing or the utilization rate in the HCV program.
6. Impact on meeting the MTW statutory goals of cost effectiveness, self-sufficiency, and/or housing choice
MTW Statutory Objective - Cost Effectiveness
This activity will increase the cost effectiveness in the public housing program. The amount of tenant rent collected will increase, and these funds will help fund self-sufficiency activities.
7. Impact on the agency's ability to meet the MTW statutory requirements
This activity will enable the NSBHA to meet both the statutory objectives of Cost Effectiveness.
8. Impact on the rate of hardship requests and the number granted and denied as a result of this activity
The NSBHA does not anticipate the number of hardship requests increasing due to the implementation of this activity.
9. Across the other factors above, the impact on protected classes (and any associated disparate impact)
This activity is implemented based on income reviews in which protected class is not a factor. Therefore, there is no anticipated impact on protected classes.
Activity 4 1.m., 1.n. Utility Reimbursements (Public Housing & HCV)
Core Questions
1. Fiscal Year Introduced: 2023
2. Fiscal Year Approved: 2023
3. Status: Implemented
4. Narrative: The NSBHA will eliminate the utility reimbursements. The goal is to increase revenue for the authority while making households more self-reliant.
The NSBHA disburses $2,127 in monthly utility reimbursements to approximately 19 public housing and HCV households, which equates to an average monthly utility reimbursement of $112 per household. The yearly average reimbursement is $1,343 per household. There are approximately 19 households that pay $0 in rent due to their utility reimbursement. Once this activity takes effect, these households must pay at least the minimum rent of $130 regardless of their utility allowance. The NSBHA will realize a minimum of $2,127 in monthly cost savings and anticipates at least a $25,524 cost savings during the first year in which this activity is implemented.
5. MTW Statutory Objectives: Cost effectiveness
6. Cost Implications: Increased revenue, Decreased expenditures
7. Policy by Household Status/Family Types/Sites: The MTW activity applies to all assisted households
8. Household Status: New admissions and currently assisted households
9. Family Types: The MTW activity applies to all family types
10. Location
For PH Activities: The MTW activity applies to all developments

Activity 5 1.v., 1.w. Alternative Income Inclusions/Exclusions (Public Housing &HCV)
Core Questions
1. Fiscal Year Introduced: 2023
2. Fiscal Year Approved: 2023

3. Status: Implemented
4. Narrative: The NSBHA will eliminate the Earned Income Disregard. This will increase operational efficiencies by reducing the time it takes to administratively process the EID.
Currently, the EID allows individuals who go from not working in the previous 12 months, to working, to gradually phase in the income counted toward their rental calculation over a period of 2 years. The EID is an opportunity for clients that gain earned income, that did not previously have earned income to experience the benefit of increased income without that income increase being utilized for rent immediately; however, due to cumbersome regulations, the cost to continue offering this exclusion far outweigh the benefits. Families will benefit from an increase in income without an immediate increase in rent.
5. MTW Statutory Objectives: Cost effectiveness, Self-sufficiency
6. Cost Implications: Decreased expenditures
7. Policy by Household Status/Family Types/Sites: The MTW activity applies only to a subset or subsets of assisted households
8. Household Status: New admissions and currently assisted households
9. Family Types: The MTW activity applies only to selected family types:
1. All families in public housing
2. Disabled families in the HCV program (to the extent those families are not exempt via a reasonable accommodation)
10. Location
For PH Activities: The MTW activity applies to all developments

12. Does this MTW activity require a hardship policy? No
13. Does the hardship policy apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
14. Has the MTW agency modified the hardship policy since the last submission of the MTW Supplement? No
15. How many hardship requests have been received associated with this activity in the most recently completed PHA fiscal year? Zero
16. Does the MTW activity require an impact analysis? No
17. Does the impact analysis apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
18. 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 has relieved the administrative burden of accounting for relief of income every year and increased NSBHA's rental income.
19. Please provide an explanation as to why the activity was discontinued or will be discontinued. N/A
Custom Questions
1. What inclusions or exclusions will be eliminated, modified, or added?
The NSBHA will eliminate the Earned Income Disregard.
Activity 6 2.b. Payment Standards-Fair Market Rents (HCV)
Core Questions
1. Fiscal Year Introduced: 2023
2. Fiscal Year Approved: 2023
3. Status: Implemented
4. Narrative: The NSBHA will raise the payment standard to 120% of the Fair Market Rents (FMR). Housing choices are dwindling due to growing local market rents, and this limits where NSBHA households can live. This activity is a remedy to this concern.The current NSBHA payment standard is 110% of the FMR. A payment standard of 120% of FMR will increase the payment standard by an average of $118 for all bedroom sizes.
5. MTW Statutory Objectives: Housing choice
6. Cost Implications: Increased expenditures
7. Policy by Household Status/Family Types/Sites: The MTW activity applies to all assisted households
8. Household Status: New admissions and currently assisted households
9. Family Types: The MTW activity applies to all family types
10. Location
For HCV Activities:
1. The MTW activity applies to all tenant-based units
2. The MTW activity applies to all properties with project-based vouchers
11. Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described? No
12. Does this MTW activity require a hardship policy? Yes
13. Does the hardship policy apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. Yes
1. Minimum Rent
2. Elimination of Deductions
3. Payment Standards - Fair Market Rents
4. Alternative Reexamination Schedule for Households
5. Work Requirement
6. FSS Alternative Family Selection Procedures
7. FSS Modify or Eliminate the Contract of Participation
8. Term Limits
14. Has the MTW agency modified the hardship policy since the last submission of the MTW Supplement? No
15. How many hardship requests have been received associated with this activity in the most recently completed PHA fiscal year? Zero
16. Does the MTW activity require an impact analysis? Yes
17. Does the impact analysis apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
18. 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.
Increasing the payment standard has helped families stay housed over the course of very high rent increases, by landlords, due to an increase in insurance costs in the state of Florida.
19. Please provide an explanation as to why the activity was discontinued or will be discontinued. N/A
Custom Questions
1. Please explain the payment standards by ZIP code or "grouped" ZIP codes.
The current NSBHA payment standard is 105% of the FMR reduced from 120% . A payment standard of 105% for all bedroom sizes in 2026 based on economic factors that were financially advantageous to reduce from 120% in 2024 to 105% in 2026.
Bedroom Size Current FMR Current PS 120% FMR-PS
0 $1205 $1265 $1446
1 $1385 $1454 $1662
2 $1700 $1785 $2040
3 $2241 $2353 $2689
4 $2429 $2550 $2915
Impact Analysis
1. Impact on the agency's finances (e.g., how much will the activity cost, any change in the agency's per family contribution
The NSBHA will raise the payment standard to 120% of the Fair Market Rents (FMR). It is anticipated that this activity will increase the NSBHA's federal expenditures in terms of housing assistance payments (HAP). The average HAP is projected to increase by $118 per family, per month. Augmenting the payment standard for FMR will expand housing choices for families and deconcentrate poverty.
2. Impact on affordability of housing costs for affected families (e.g., any change in how much affected families will pay towards their housing costs)
Families will, similarly, see an increase in their tenant rent portion; however, it will be insubstantial. Due to increases in local market rents, all families will see an increase in rent regardless of their income status.
3. Impact on the agency's waitlist(s) (e.g., any change in the amount of time families are on the waitlist)
This activity will not affect the waiting list.
4. Impact on the agency's termination rate of families (e.g., any change in the rate at which families non-voluntarily lose assistance from the agency)
This activity will not affect the termination rate of families.
5. Impact on the agency's current occupancy level in public housing and utilization rate in the HCV program
Due to an increase in HAP, this activity may affect the agency's current utilization rate in the HCV program. It is the expectation that this activity will have a neutral effect on the HCV utilization rate when combined and implemented with the other NSBHA MTW activities.
6. Impact on meeting the MTW statutory goals of cost effectiveness, self-sufficiency, and/or housing choice
MTW Statutory Objective - Housing Choice
This activity will enlarge the pool of available and affordable housing choices from which a family can choose.
7. Impact on the agency's ability to meet the MTW statutory requirements
The NSBHA will be able to meet the statutory objective of Housing Choice.
8. Impact on the rate of hardship requests and the number granted and denied as a result of this activity
The NSBHA does not expect to see an increase in hardship requests as a result of this activity.
9. Across the other factors above, the impact on protected classes (and any associated disparate impact)
This activity is based on income reviews, in which protected class is not a factor, and there is no anticipated impact on protected classes. Elderly and disabled participants are a protected class; however, this activity will not have a negative impact on them.

Activity 7 3.a., 3.b. Alternative Recertification Schedule for Households (PH & HCV)
Core Questions

1. Fiscal Year Introduced: 2023
2. Fiscal Year Approved: 2023
3. Status: Implemented
4. Narrative
The NSBHA will decrease the frequency of tenant reexaminations from annual to triennial for all public housing and HCV households. This restructuring will allow families to have a more consistent rent portion over a longer period of time, and it will create more time for the NSBHA staff to attend to other business affairs.

Interim recertifications will be limited to one interim per year at the request of the household. If the interim is for a decrease in income, only income decreases of 10% or more will be processed. Interim decreases will be limited to one during a calendar year and no interim decreases during the first six months after initial occupancy. Required interim recertifications for household composition changes or landlord rent increases will not count against the limit on voluntary interim recertifications.
5. MTW Statutory Objectives: Cost effectiveness
6. Cost implications: Decreased expenditures
7. Policy by household status/family types/sites: The MTW activity applies to all assisted households
8. Household Status: New admissions and currently assisted households
9. Family Types: The MTW activity applies to all family types

10. Location
For PH Activities:
1. The MTW activity applies to all developments
2. For HCV Activities:
1. The MTW activity applies to all tenant-based units
2. The MTW activity applies to all properties with project-based vouchers3.
11. Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described? No
12. Does this MTW activity require a hardship policy? Yes
13. Does the hardship policy apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. Yes
1. Minimum Rent
2. Elimination of Deductions
3. Payment Standards - Fair Market Rents
4. Alternative Recertifications Schedule
5. Work Requirement
6. FSS Alternative Family Selection Procedures
7. FSS Modify or Eliminate the Contract of Participation
8. Term Limits
14. Has the MTW agency modified the hardship policy since the last submission of the MTW Supplement? No
15. How many hardship requests have been received associated with this activity in the most recently completed PHA fiscal year? Zero
16. Does the MTW activity require an impact analysis? Yes
17. Does the impact analysis apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
18. 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 started in calendar year 2022 (FY23), which means, in 2025, the NSBHA reached a recertification schedule where it only processes one-third of annual recertifications. In other words, NSBHA only processes full recertifications four months out of the year. This has drastically reduced staff time in completing recertifications and, as soon as the Housing Information Portal (HIP) is released, it will reduce this even further. This activity has streamlined recertifications insomuch that the NSBHA has been able to reduce the HCV staff by one employee.
19. Please provide an explanation as to why the activity was discontinued or will be discontinued. N/A
Custom Questions
1. What is the recertification schedule?
Once every three years for able-bodied, elderly and/or disabled, and VASH households.
2. How many interim recertifications per year may a household request? 1
3. Please describe briefly how the MTW agency plans to address changes in family/household circumstances under the alternative reexamination schedule.
Required interim recertifications for household composition changes or landlord rent increases will not count against the limit on voluntary interim recertifications.
Impact Analysis
1. Impact on the agency's finances (e.g., how much will the activity cost, any change in the agency's per family contribution
The NSBHA will decrease the frequency of tenant reexaminations from annual to triennial for all of its public housing and HCV households, including Veterans Affairs Supportive Housing (VASH) voucher holders. The NSBHA predicts that this activity will produce operational cost savings, as staff are freed to manage other administrative affairs.
2. Impact on affordability of housing costs for affected families (e.g., any change in how much affected families will pay towards their housing costs)
This activity will allow the NSBHA's households to have a more consistent tenant rent portion over a longer period of time, which will consequently make the public housing and HCV programs more affordable for families.

3. Impact on the agency's waitlist(s) (e.g., any change in the amount of time families are on the waitlist)
This activity will not affect the waiting list.
4. Impact on the agency's termination rate of families (e.g., any change in the rate at which families non-voluntarily lose assistance from the agency)
This activity will not affect the termination rate of families.
5. Impact on the agency's current occupancy level in public housing and utilization rate in the HCV program
This activity will not affect the agency's current public housing occupancy level or utilization rate in the HCV program.
6. Impact on meeting the MTW statutory goals of cost effectiveness, self-sufficiency, and/or housing choice
MTW Statutory Objective - Cost Effectiveness
This activity will decrease the administrative costs associated with processing annual and interim recertifications.
7. Impact on the agency's ability to meet the MTW statutory requirements
The NSBHA will be able to meet the statutory objective of Cost Effectiveness.
8. Impact on the rate of hardship requests and the number granted and denied as a result of this activity
The NSBHA does not expect to see an increase in hardship requests as a result of this activity.
9. Across the other factors above, the impact on protected classes (and any associated disparate impact)
This activity is based on income reviews, in which protected class is not a factor, and there is no anticipated impact on protected classes.

Activity 8 3.c., 3.d. Self-Certification of Assets (Public Housing and HCV)
Core Questions
1. Fiscal Year Introduced: 2023
2. Fiscal Year Approved: 2023
3. Status: Implemented
4. Narrative: The asset self-certification ceiling will be increased from $5,000 to $50,000. This will lessen the regulatory responsibilities of the NSBHA.
5. MTW Statutory Objectives: Cost effectiveness
6. Cost Implications: Decreased expenditures
7. Policy by Household Status/Family Types/Sites: The MTW activity applies to all assisted households
8. Household Status: New admissions and currently assisted households
9. Family Types: The MTW activity applies to all family types
10. Location
For PH Activities:
1. The MTW activity applies to all developments
For HCV Activities:
1. The MTW activity applies to all tenant-based units
2. The MTW activity applies to all properties with project-based vouchers2.
11. Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described? No
12. Does this MTW activity require a hardship policy? No
13. Does the hardship policy apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
14. Has the MTW agency modified the hardship policy since the last submission of the MTW Supplement? No
15. How many hardship requests have been received associated with this activity in the most recently completed PHA fiscal year? Zero
16. Does the MTW activity require an impact analysis? No

17. Does the impact analysis apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
18. 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 has streamlined the recertification process by reducing the time needed for staff to complete them. Not many families have assets over $50,000.
19. Please provide an explanation as to why the activity was discontinued or will be discontinued. N/A
Custom Questions
1. Please state the dollar threshold for the self-certification of assets. $50,000
Activity 9 5.d. Alternative Inspection Schedule (HCV)
Core Questions
1. Fiscal Year Introduced: 2023
2. Fiscal Year Approved: 2023
3. Status: Not implemented
4. Narrative: The NSBHA will establish a triennial inspection schedule for all HCV units in accordance with HQS inspection standards as outlined in 24 CFR 982.401. HCV participants may request an interim inspection, and HUD may conduct or direct the NSBHA to perform an inspection at any time for health and safety or accessibility purposes.
5. MTW Statutory Objectives: Cost effectiveness
6. Cost Implications: Increased revenue, Decreased expenditures
7. Policy by Household Status/Family Types/Sites: The MTW activity applies to all assisted households
8. Household Status: New admissions and currently assisted households
9. Family Types: The MTW activity applies to all family types
10. Location
3. For HCV Activities:
1. The MTW activity applies to all tenant-based units
2. The MTW activity applies to all properties with project-based vouchers4.
11. Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described? No
12. Does this MTW activity require a hardship policy? No
13. Does the hardship policy apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
14. Has the MTW agency modified the hardship policy since the last submission of the MTW Supplement? No
15. How many hardship requests have been received associated with this activity in the most recently completed PHA fiscal year? Zero
16. Does the MTW activity require an impact analysis? No
17. Does the impact analysis apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
18. 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.
The NSBHA has not implemented the triennial inspections; the NSBHA is still performing biennial inspections. The NSBHA will implement this activity once HIP and the NSBHA's Enterprise Resource Planning (ERP) software are ready.
19. Please provide an explanation as to why the activity was discontinued or will be discontinued. N/A
Activity 10 9.b. Increase PBV Project Cap (HCV)
Core Questions
1. Fiscal Year Introduced: 2023
2. Fiscal Year Approved: 2023
3. Status: Implemented
4. Narrative: The NSBHA will increase the cap on the percentage of project-based vouchers (PBVs) that can be project based in a building or project from 25% to 100%. This will allow the NSBHA to offer more housing choices to families.
5. MTW Statutory Objectives: Cost effectiveness, Housing choice
6. Cost Implications: Increased revenue
7. Policy by Household Status/Family Types/Sites: The MTW activity applies to all assisted households
8. Household Status: New admissions and currently assisted households
9. Family Types: The MTW activity applies to all family types
10. Location
5. For HCV Activities: The MTW activity applies to all properties with project-based vouchers
11. Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described? No
12. Does this MTW activity require a hardship policy? No
13. Does the hardship policy apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
14. Has the MTW agency modified the hardship policy since the last submission of the MTW Supplement? No
15. How many hardship requests have been received associated with this activity in the most recently completed PHA fiscal year? 0
16. Does the MTW activity require an impact analysis? No
17. Does the impact analysis apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
18. 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.
The NSBHA implemented this activity with the Greenlawn Manor Low-Income Housing Tax Credit (LIHTC) property. Eighty-eight percent of the property was utilized by PBV.
The agency is in repositioning 80 public housing units that will utilize 80 PBV's in 2 properties with 136 units.
19. Please provide an explanation as to why the activity was discontinued or will be discontinued. N/A
Activity 11 12.a., 12.b. Work Requirement (Public Housing & HCV)
Core Questions
1. Fiscal Year Introduced: 2025
2. Fiscal Year Approved: 2025
3. Status: Implemented beginning January 2025
4. Narrative
The NSBHA will implement a mandatory work requirement for all non-elderly and non-disabled individuals between the ages of 18 and 62. These individuals must work a minimum of 15 hours per week.
Eligible individuals will meet with the NSBHA staff to determine the best course of action, on an individual basis, to meet this activity's ultimate goal of self-sufficiency. The NSBHA, at its discretion, will allow acceptable substitutes for employment, such as education, job training, or rehabilitation to fulfill this requirement.
The following individuals will be exempt from this activity: individuals that are exempt from the Community Service Requirement, elderly and/or disabled individuals, individuals aged 18 years and younger, live-in aides, individuals that are the primary caretaker for a child under 6 years of age, and women who are pregnant.
The NSBHA has implemented not only work requirements, but also term limits and is finding that a minimum of 15 hours worked per week is not enough to prepare able-bodied residents and participants for self-sufficiency. The inception of term limits obligates the NSBHA to prepare affected individuals for program graduation or a life without housing subsidy. Although the majority of affected individuals are already working the required minimum number of hours, today's economy demands that either pay rates increase and/or the number of working hours increase. The NSBHA can influence the number of hours worked, and, as so, is augmenting this waiver by increasing the required minimum number of hours worked per week from 15 to 20. Every year thereafter, affected individuals will be required to increase the number of working hours per week by 10 hours every year until he or she reaches full-time employment (40 hours per week). There is no limit to the number of jobs affected individuals may have as long as the number of work hours are complied. These changes are in alignment with the ideals of HUD's Work and Dignity Coalition, of which the NSBHA is a member.
5. MTW Statutory Objectives: Cost effectiveness, Self-sufficiency
6. Cost Implications: Increased revenue, Decreased expenditures

7. Policy by Household Status/Family Types/Sites: The MTW activity applies only to a subset or subsets of assisted households
8. Household Status: New admissions and currently assisted households
9. Family Types: The MTW activity applies only to selected family types: Non-elderly, non-disabled families
10. Location
For PH Activities:
The MTW activity applies to all developments
For HCV Activities:
1. The MTW activity applies to all tenant-based units
2. The MTW activity applies to all properties with project-based vouchers3.
11. Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described? Yes - Certain provisions of sections 6(l)(1) and 6(l)(5) of the 1937 Act and 24 CFR. 966.4(a)(2) for Public Housing, and certain provisions of 24 CFR982.55 for HCV.
12. Does this MTW activity require a hardship policy? Yes
13. Does the hardship policy apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. Yes
1. Minimum Rent
2. Alternative Recertification Schedule For Households
3. Elimination of Deductions
4. Payment Standards - Fair Market Rents
5. Work Requirement
6. FSS Alternative Family Selection Procedures
7. FSS Modify or Eliminate the Contract of Participation
8. Term Limits
14. Has the MTW agency modified the hardship policy since the last submission of the MTW Supplement? No
15. How many hardship requests have been received associated with this activity in the most recently completed PHA fiscal year? Two
16. Does the MTW activity require an impact analysis? Yes
17. Does the impact analysis apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
18. 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.
The NSBHA implemented this activity in January 2025. Ninety-nine percent of affected individuals are now working. For the FY28, the NSBHA is expanding this activity by increasing the number of required working hours as outlined in the narrative above.
19. Please provide an explanation as to why the activity was discontinued or will be discontinued. N/A
Custom Questions
1. 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? No
2. What counts as "work" under this the work requirement MTW activity?: Part-time, full-time, and seasonal employment
3. How will the MTW agency monitor compliance with the work requirement MTW activity?
Compliance will be monitored by the NSBHA through yearly prescheduled reviews and triennial recertifications. Compliance will also be monitored through the residents and participants themselves, as they must report any non-compliance to the work requirement to the NSBHA within 10 days.
4. What supportive services are offered to support households to comply with the work requirement?
Supportive services will be offered through the NSBHA staff and/or a community partner of the NSBHA. The NSBHA has partnered with the service providers below to provide services to residents and participants. The NSBHA fully intends to partner with additional agencies in the community to broaden the services offered.

Career Source provides the following to residents and participants:
1. Assessments
2. Bureau of Labor Statistics (BLS) Data matching, which assists in planning career paths, based on existing skills
3. Advocacy/outreach to identify local employers committed to the hiring of persons with disabilities
4. Skills training (résumé writing, interviewing skills, obtaining and maintaining employment)
5. Navigation of disability services
6. On-the-job training
7. Information and referrals
8. Training grants
The Department of Children & Families provides the following to residents and participants:
1. Assistance with food stamps
2. Medicaid
The Early Learning Coalition provides the following to residents and participants:
1. Childcare resources & referrals
2. Challenging behavior supports
3. Child screening
4. School readiness
5. Voluntary Prekindergarten Education (VPK)
Daytona State College provides the following to residents and participants:
1. Financial aid assistance
2. Certifications
3. Degrees
4. Guidance counseling

SMA Healthcare provides the following to residents and participants:
1. Substance abuse treatment
2. Mental health treatment/counseling
The Volusia County Library provides computer access for job searches and resume creation for residents and participants.
5. How does the agency address noncompliance with the work requirement policy?
Residents and participants will have 10 days to report non-compliance. If the lack of compliance is not due to a hardship, the NSBHA will issue a written warning and the resident must gain employment within six months. The NSBHA will also refer the resident or participant to one of NSBHA's community partners for services, of which the resident or participant must attend. The resident or participant must check in monthly with the NSBHA regarding the progress of his/her job search. If in good faith the resident or participant has not obtained employment in six months, the NSBHA will extend the job search for another 60 days. If the or participant has not obtained employment in six months, has failed to check-in with the NSBHA, and has failed to participate in the employment services offered, the NSBHA will terminate the resident or participant's participation in the public housing or HCV program.

If the resident or participant fails to give notice within 10 days, the resident or participant will receive a "curable" deficiency notice from the NSBHA stating the resident or participant's non-compliance. Additionally, the letter will state the requirements for the resident or participant, which includes finding employment within 90 days, checking in monthly with the NSBHA, and partaking in services with the NSBHA's community partner. If in good faith the resident or participant has not obtained employment in three months, the NSBHA will extend the job search for another 30 days. If the resident or participant has not obtained employment in three months, has failed to check-in with the NSBHA, and has failed to participate in the employment services offered, the NSBHA will terminate the resident or participant's participation in the public housing or HCV program.

If the resident or participant fails to give notice within 10 days, the resident or participant will receive a "curable" deficiency notice from the NSBHA stating the resident or participant's non-compliance. If the resident or participant completely disregards the "curable" deficiency notice, the NSBHA will terminate the resident or participant's participation in the public housing or HCV program.

6. How many households are currently subject to the policy?: 107 households
7. How many households in the most recently completed PHA fiscal year were sanctioned for non-compliance with the work requirement? Zero
Impact Analysis
1. Impact on the agency's finances (e.g., how much will the activity cost, any change in the agency's per family contribution
The NSBHA will implement a work requirement for individuals aged 18 years and older. Tenant rent and the tenant portion of rent may increase because of this activity. If so, the increased tenant rent will increase revenue for the NSBHA, and the increased tenant portion of rent will decrease HAP for the NSBHA.
2. Impact on affordability of housing costs for affected families (e.g., any change in how much affected families will pay towards their housing costs)
This activity will provide a neutral effect on the affordability for NSBHA families. The increase in income received from families will affect their tenant rent or tenant portion of rent. The additional funds received and the decrease in HAP will be utilized to increase resident services and increase the payment standard. Mandatory employment and other NSBHA supportive services will allow families to afford the progressive rent preparing them for program graduation.
3. Impact on the agency's waitlist(s) (e.g., any change in the amount of time families are on the waitlist): This activity will not affect the waiting list.
4. Impact on the agency's termination rate of families (e.g., any change in the rate at which families non-voluntarily lose assistance from the agency): This activity will not affect the termination rate of families.
5. Impact on the agency's current occupancy level in public housing and utilization rate in the HCV program: This activity will not affect the agency's current occupancy level in public housing or the utilization rate in the HCV program.
6. Impact on meeting the MTW statutory goals of cost effectiveness, self-sufficiency, and/or housing choice: MTW Statutory Objective - Cost Effectiveness
This activity will increase the tenant rent for families and increase the revenue received by the NSBHA in the public housing program. This activity will increase the tenant portion of rent for families and decrease the HAP given to landlords by the NSBHA in the HCV program.

MTW Statutory Objective - Self Sufficiency
This activity will obligate able-bodied individuals to work; thereby, allowing them to accumulate funds in preparation of program graduation.
7. Impact on the agency's ability to meet the MTW statutory requirements: The NSBHA will be able to meet the statutory objectives of Cost Effectiveness and Self-Sufficiency.
8. Impact on the rate of hardship requests and the number granted and denied as a result of this activity
The NSBHA does not anticipate the number of hardship requests increasing due to the implementation of this activity. The NSBHA has an all-encompassing program of supportive services to mitigate such hardships should they arise.
9. Across the other factors above, the impact on protected classes (and any associated disparate impact)
This activity is based on able-bodied individuals, in which protected class is not a factor, and there is no anticipated impact on protected classes.

Activity 12 10.c. FSS Alternative Family Selection Procedures (PH &HCV)
Core Questions
1.Fiscal Year Introduced: 2025
2.Fiscal Year Approved: 2025
3.Status: Implemented January 2025
4.Narrative:
To increase graduation rates from low-income housing, the NSBHA will make the participation in the Family Self-Sufficiency (FSS) program mandatory for all able-bodied HCV and PH individuals.
Able-bodied HCV participants and PH residents currently enrolled in the FSS program must continue to participate in the FSS program until program graduation as a condition of housing. Their Contract of Participation (CoP) for the FSS program is five (5) years.
Current able-bodied HCV participants and PH residents NOT currently enrolled in the FSS program and new residents and participants admitted to the HCV or PH programs must participate in the new expanded FSS program. The CoP for the expanded FSS program is nine (9) years.
All current port-in voucher holders and all incoming port-in voucher holders will be absorbed and will be subject to mandatory participation in the new expanded FSS program.
Elderly and disabled participants and residents are exempt from both the FSS and the new expanded FSS programs. They may participate in the either of the programs, by choice.
5.MTW Statutory Objectives: Self-sufficiency
6.Cost Implications: Neutral
7. Policy by Household Status/Family Types/Sites: The MTW activity applies to only a subset or subsets of assisted households
8.Household Status: Currently assisted households
9. Family Types: The MTW activity applies only to selected family type: Non-elderly, non-disabled families
10. Location
6. For PH Activities:
The MTW activity applies to all developments
7. For HCV Activities:
1.The MTW activity applies to all tenant-based units
2.The MTW activity applies to all properties with project-based vouchers
11.Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described? No
12. Does this MTW activity require a hardship policy? Yes
13. Does the hardship policy apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. Yes
1. Minimum Rent
2. Elimination of Deductions
3. Payment Standards - Fair Market Rents
4. Alternative Reexamination Schedule for Households
5. Work Requirement
6. FSS Alternative Family Selection Procedures
7. FSS Modify or Eliminate the Contract of Participation
8. Term Limits
14.Has the MTW agency modified the hardship policy since the last submission of the MTW Supplement? No
15.How many hardship requests have been received associated with this activity in the most recently completed PHA fiscal year? Two
16.Does the MTW activity require an impact analysis? No
17.Does the impact analysis apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
18. 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.
The NSBHA implemented this activity in January 2025. Ninety-eight percent of able-bodied families have enrolled in the FSS program. Of the five graduates, in 2025, four of those families left assisted housing and either went to homeownership or moved into market rate housing and became self-sufficient allowing other families on the waitlist the opportunity to also become self-sufficient.
19.Please provide an explanation as to why the activity was discontinued or will be discontinued. N/A
CUSTOM QUESTIONS
1.Please describe the purpose and goals of the alternative contract or locally developed agreement, and/or the MTW agency's motivation for developing its own contract or agreement.
Participation in the Family Self-Sufficiency program will now be mandatory for all able-bodied HCV and PH individuals.
Impact Analysis
1.Impact on the agency's finances (e.g., how much will the activity cost, any change in the agency's per family contribution
The NSBHA is making participation in the Family Self-Sufficiency (FSS) program mandatory for all able-bodied HCV and PH individuals, including current and incoming ports. This will produce a neutral effect on the agency's finances. The increase in rent revenue received, via PH families, and the decrease in HAP paid for HCV families will then be put into escrow for families as a reward for achieving their self-sufficiency goals.
2.Impact on affordability of housing costs for affected families (e.g., any change in how much affected families will pay towards their housing costs)
This activity will be employed in tandem with a minimum rent and work requirement. The impact on affordability will also have a neutral effect. Rents will increase in parallel with the increased income of families; however, now an incentive is being given for that. Not only will the family's overall income increase, but it will also prepare them for program graduation with a nice reward at the end. This activity will affect all able-bodied individuals within 122 households.
3.Impact on the agency's waitlist(s) (e.g., any change in the amount of time families are on the waitlist)
This activity will not affect the waiting list.
4.Impact on the agency's termination rate of families (e.g., any change in the rate at which families non-voluntarily lose assistance from the agency)
This activity will not affect the termination rate of families.
5.Impact on the agency's current occupancy level in public housing and utilization rate in the HCV program
This activity will not affect the agency's current occupancy level in public housing or the utilization rate in the HCV program.
6.Impact on meeting the MTW statutory goals of cost effectiveness, self-sufficiency, and/or housing choice
MTW Statutory Objective - Self-Sufficiency
This activity will obligate able-bodied individuals to participate in the FSS program and actively make and achieve goals that lead towards self-sufficiency.
7.Impact on the agency's ability to meet the MTW statutory requirements
The NSBHA will be able to meet the statutory objectives of Cost Effectiveness and Self-Sufficiency.
8.Impact on the rate of hardship requests and the number granted and denied as a result of this activity
The NSBHA does not anticipate the number of hardship requests increasing due to the implementation of this activity.
9.Across the other factors above, the impact on protected classes (and any associated disparate impact)
This activity is implemented based on income reviews in which protected class is not a factor. Therefore, there is no anticipated impact on protected classes.

Activity 13 10.d. FSS Modify or Eliminate the Contract of Participation (PH & HCV)
Core Questions
1. Fiscal Year Introduced: 2026
2. Fiscal Year Approved: 2026
3. Status: Started in 2026
4. Narrative
To increase graduation rates from low-income housing, the NSBHA will expand the Family Self-Sufficiency (FSS) Contract of Participation (CoP) from five (5) years to up to nine (9) years. The NSBHA will make the participation in the Family Self-Sufficiency (FSS) program mandatory for all able-bodied HCV participants and PH residents NOT currently enrolled in the FSS program and for new residents and participants admitted to the HCV or PH programs.

All current port-in voucher holders and all incoming port-in voucher holders will be absorbed and will be subject to mandatory participation in the expanded FSS program with a CoP of up to nine (9) years.
Able-bodied HCV participants and PH residents currently enrolled in the FSS program must continue to participate in the regular FSS program until program graduation as a condition of housing. Their CoP is five years and are exempt from the nine years CoP.
5. MTW Statutory Objectives: Self-sufficiency
6. Cost Implications: Neutral
7. Policy by Household Status/Family Types/Sites: The MTW activity applies to only a subset or subsets of assisted households
8. Household Status: New admissions and currently assisted households not enrolled in the FSS program.
9. Family Types: The MTW activity applies only to selected family type: Non-elderly, non-disabled families
10. Location
8. For PH Activities: The MTW activity applies to all developments

9. For HCV Activities:
1. The MTW activity applies to all tenant-based units
2. The MTW activity applies to all properties with project-based vouchers
11. Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described? No
12. Does this MTW activity require a hardship policy? Yes
13. Does the hardship policy apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. Yes
1. Minimum Rent
2. Elimination of Deductions
3. Payment Standards - Fair Market Rents
4. Alternative Reexamination Schedule for Households
5. Work Requirement
6. FSS Alternative Family Selection Procedures
7. FSS Modify or Eliminate the Contract of Participation
8. Term Limits
14. Has the MTW agency modified the hardship policy since the last submission of the MTW Supplement? No
15. How many hardship requests have been received associated with this activity in the most recently completed PHA fiscal year? Zero
16. Does the MTW activity require an impact analysis? Yes
17. Does the impact analysis apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
18. 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 will be implemented in January 2026.
19. Please provide an explanation as to why the activity was discontinued or will be discontinued. N/A
Impact Analysis
1. Impact on the agency's finances (e.g., how much will the activity cost, any change in the agency's per family contribution
The NSBHA does not anticipate an impact on the agency's finances, as families will accrue escrow funds based on changes in their income. Besides providing oversight, this activity does not require the NSBHA to disburse any additional funds.
2. Impact on affordability of housing costs for affected families (e.g., any change in how much affected families will pay towards their housing costs)
The NSBHA does not anticipate an impact on the affordability of housing cost for families.
3. Impact on the agency's waitlist(s) (e.g., any change in the amount of time families are on the waitlist)
This activity will not affect the waiting list.

4. Impact on the agency's termination rate of families (e.g., any change in the rate at which families non-voluntarily lose assistance from the agency)
This activity will not affect the termination rate of families.
5. Impact on the agency's current occupancy level in public housing and utilization rate in the HCV program
This activity will not affect the agency's current occupancy level in public housing or the utilization rate in the HCV program.
6. Impact on meeting the MTW statutory goals of cost effectiveness, self-sufficiency, and/or housing choice
MTW Statutory Objective - Self-Sufficiency
This activity will give FSS participants added time to accrue additional funds in anticipation of program graduation.
7. Impact on the agency's ability to meet the MTW statutory requirements
The NSBHA will be able to meet the statutory objectives of self-sufficiency.
8. Impact on the rate of hardship requests and the number granted and denied as a result of this activity
The NSBHA does not anticipate the number of hardship requests increasing due to the implementation of this activity.
9. Across the other factors above, the impact on protected classes (and any associated disparate impact)
This activity is implemented based on income reviews in which protected class is not a factor. Therefore, there is no anticipated impact on protected classes.
Activity 14 7.a., 7.b. Term Limits (PH & HCV)
Core Questions
1. Fiscal Year Introduced: 2026
2. Fiscal Year Approved: 2026
3. Status: Implemented 2026
4. Narrative
The NSBHA will institute up to a nine (9) year housing term limit for able-bodied residents and participants. All current port-in voucher holders and all incoming port-in voucher holders will be absorbed and will also be subject to the nine (9) year housing term limit. This activity is being introduced simultaneously with an expanded FSS program, which prepares families for either homeownership or unsubsidized rent and a minimum work requirement. This activity allows the NSBHA to assist other low-income families in need and thwarts intergenerational poverty. The NSBHA has expanded its FSS program to coincide with the term limits to facilitate the transition off of subsidy for families.
5. MTW Statutory Objectives: Self-sufficiency
6. Cost Implications: Neutral
7. Policy by Household Status/Family Types/Sites: The MTW activity applies to only a subset or subsets of assisted households
8. Household Status: New admissions and currently assisted households
9. Family Types: The MTW activity applies only to selected family type: Non-elderly, non-disabled families
10. Location
For PH Activities: The MTW activity applies to all developments
For HCV Activities:
1. The MTW activity applies to all tenant-based units
2. The MTW activity applies to all properties with project-based vouchers
11. Does the MTW agency need a Safe Harbor Waiver to implement this MTW activity as described? No
12. Does this MTW activity require a hardship policy? Yes
13. Does the hardship policy apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. Yes
1. Minimum Rent
2. Elimination of Deductions
3. Payment Standards - Fair Market Rents
4. Alternative Reexamination Schedule for Households
5. Work Requirement
6. FSS Alternative Family Selection Procedures
7. FSS Modify or Eliminate the Contract of Participation
8. Term Limits
14. Has the MTW agency modified the hardship policy since the last submission of the MTW Supplement? N/A
15. How many hardship requests have been received associated with this activity in the most recently completed PHA fiscal year? Zero
16. Does the MTW activity require an impact analysis? Yes
17. Does the impact analysis apply to more than this MTW activity? If yes, then please list all of the applicable MTW activities. No
18. 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.
Term limits for new admissions has already begun. For current residents and participants, term limits will begin at their next triennial recertification. For current residents and participants whose triennial recertification is in 2026, they will stay in the program until their lease expires in 2035 or earlier. For current residents and participants whose triennial recertification is in 2027, they will stay in the program until their lease expires in 2036. For current residents and participants whose triennial recertification is in 2028, they will stay in the program until their lease expires in 2037.
19. Please provide an explanation as to why the activity was discontinued or will be discontinued. N/A
Custom Questions
1. Does the term-limited assistance MTW activity exempt any type of household or individual other than the elderly or individuals with disabilities? No
2. Please describe how the MTW agency supports households to prepare for the end of assistance.
The NSBHA has instituted an expanded FSS program, of which participation is mandatory. This program will prepare families for either homeownership or unsubsidized rent.

3. How many households are currently subject to this policy?: 122 households
IMPACT ANALYSIS
1. Impact on the agency's finances (e.g., how much will the activity cost, any change in the agency's per family contribution
The NSBHA does not anticipate an impact on the agency's finances.
2. Impact on affordability of housing costs for affected families (e.g., any change in how much affected families will pay towards their housing costs)
The NSBHA does not anticipate an impact on the affordability of housing cost for families.
3. Impact on the agency's waitlist(s) (e.g., any change in the amount of time families are on the waitlist)
This activity will not affect the waiting list.
4. Impact on the agency's termination rate of families (e.g., any change in the rate at which families non-voluntarily lose assistance from the agency)
This activity will not affect the termination rate of families.
5. Impact on the agency's current occupancy level in public housing and utilization rate in the HCV program
This activity will not affect the agency's current occupancy level in public housing or the utilization rate in the HCV program.
6. Impact on meeting the MTW statutory goals of cost effectiveness, self-sufficiency, and/or housing choice
MTW Statutory Objective - Self-Sufficiency
This will provide additional incentive for families to become more thoughtful about their financial futures in terms of housing. Also this activity will, hopefully, encourage or help to change the mindsets of families allowing them to see themselves as more than just being low-income, but families with unlimited possibilities ahead of them.
7. Impact on the agency's ability to meet the MTW statutory requirements
The NSBHA will be able to meet the statutory objectives of self-sufficiency.

8. Impact on the rate of hardship requests and the number granted and denied as a result of this activity
The NSBHA does not anticipate the number of hardship requests increasing due to the implementation of this activity.
9. Across the other factors above, the impact on protected classes (and any associated disparate impact)
This activity is implemented based on a term limit, in which protected class is not a factor. Therefore, there is no anticipated impact on protected classes.
D. Safe Harbor Waivers
D.1 Safe Harbor Waivers seeking HUD Approval:
The MTW Operations Notice describes a simplified process for MTW agencies to implement MTW activities outside of the safe harbors described in Appendix I. For each Safe Harbor Waiver request, a document that includes the following information must be provided: (a) the name and number of the MTW Waiver and associated activity for which the MTW agency is seeking to expand the safe harbor, (b) the specific safe harbor and its implementing regulation, (c) the proposed MTW activity the MTW agency wishes to implement via this Safe Harbor Waiver, (d) a description of the local issue and why such an expansion is needed to implement the MTW activity, (e) an impact analysis, (f) a description of the hardship policy for the MTW activity, if applicable, and (g) 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 request for approval of a Safe Harbor Waiver this year?
Yes
E. Agency-Specific Waivers
E.1 Agency-Specific Waivers 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:
For each previously approved Agency-Specific Waiver(s), a set of questions will populate. Does the MTW agency have any approved Agency-Specific Waivers?
No
F. Public Housing Operating Subsidy Grant Reporting
Please provide the total number of unit months that families were housed in a local, non-traditional housing development program for the prior full calendar year.
230 unit months
How many units, developed under the local, non-traditional housing development activity, were available for occupancy during the prior full calendar year (by bedroom size)?
Please include only those units that serve household at or below 80% of AMI in the table provided.
Property Name, Bedroom Size, Total Units, Population Type, # of Section 504 Accessible (Mobility), # of Section 504 Accessible (Hearing, Vision), Was this Property Made Available for Initial Occupancy during the Prior Fill Calendar Year?, What was the Total Amount of MTW Funds Invested into the Property?
1. 607 Washington St., 3 BR, 1 Unit, Family, 0, 0, Yes, N/A
2. 22 Marilyn Ave., 2 BR, 1 Unit, Disabled, 0, 0, No, N/A
3. 24 Marilyn Ave., 2 BR, 1 Unit, Disabled, 0, 0, No, N/A
4. 115 W. Turgot, 2 BR, 1 Unit, Family, 0, 0, Yes, N/A
5. 117 W. Turgot, 2BR, 1 Unit, Family, 0, 0, Yes, N/A
6. 1575 Julia St., 3 BR, 1 Unit, Family, 0, 0, No, N/A
7. 19 Pine Brook, 4 BR, 1 Unit, Family, 0, 0, No, N/A
8. 200 Dimmick St., 2 BR, 1 Unit, Family, 0, 0, Yes, N/A
9. 523 Julia St., 3 BR, 1 Unit, Family, 0, 0, No, N/A
10. 525 Julia St., 3 BR, 1 Unit, Family, 0, 0, No, N/A
11. 527 Julia St., 2 BR, 1 Unit, Family, 0, 0, Yes, N/A
12. 520 Julia St., 3 BR, 1 Unit, Family, 0, 0, No, N/A
13. 124 Railroad St., 3 BR, 1 Unit, 0, 0, Yes, N/A
14. 126 Railroad St., 3 BR, 1 Unit, 0, 0, No, N/A
15. 128 Railroad St., 3 BR, 1 Unit, 0, 0, Yes, N/A
16. 130 Railroad St., 3 BR, 1 Unit, 0, 0, Yes, N/A
17. 132 Railroad St., 3 BR, 1 Unit, 0, 0, Yes, N/A
18. 201 Dimmick St., 2BR, 1 Unit, Elderly, 1, 1, No, N/A
19. 203 Dimmick St., 2 BR, 1 Unit, Elderly, 1, 1, No, N/A
20. 205 Dimmick St., 0/1 BR, 1 Unit, Elderly, 1, 1, No, N/A
21. 207 Dimmick St., 0/1 BR, 1 Unit, Elderly, 1, 1, No, N/A
22. 900 Roper St., 4 BR, 1 Unit, Family, 0,0, Yes, N/A
Total 0/1 Bedroom Units: 2
Total 2 Bedroom Units: 8
Total 3 Bedroom Units: 10
Total 4 Bedroom Units: 2
Total # of Section 504 Accessible (Mobility): 4
Total # of Section 504 Accessible (Hearing/Vision): 4
Total Units: 22
* User will select one of the following from the "Population Type" dropdown box: General, Elderly, Disabled, Elderly/Disabled, Other
If the "Population Type" of is Other is selected, please state the Property Name/Address and describe the population type. [Text box]
** The federal accessibility standard under HUD's Section 504 regulation is the Uniform Federal Accessibility Standards (UFAS) for purposes of Section 504 compliance. HUD recipients may alternatively use the 2010 ADA Standards for Accessible Design under Title II of the ADA, except for certain specific identified provisions, as detailed in HUD's Notice on "Instructions for use of alternative accessibility standard," published in the Federal Register on May 23, 2014 ("Deeming Notice") for purposes of Section 504 compliance, https://www.govinfo.gov/content/pkg/FR-2014-05-23/pdf/2014-11844.pdf. This would also include adaptable units as defined by HUD's Section 504 regulation (See 24 CFR § 8.3 and § 8.22).
G. 4 Comparable Mix (by Family Size)- Local, Non-Traditional
In order to demonstrate that the MTW statutory requirement of "maintaining a comparable mix of families (by family size) are served, as would have been provided had the amounts not been used under the demonstration" is being achieved, the MTW agency will provide information for its most recently completed Fiscal Year in the following table. Local, non-traditional family size data must be provided in the MTW Supplement form until such time that it can be submitted in IMS-PIC or other HUD system.
Family Size, Occupied Number of Local, Non-Traditional units by Household Size:
1 Person: 4
2 Person: 3
3 Person: 5
4 Person: 7
5 Person: 1
6+ Person: 0
Totals: 20
G.5 Housing Quality Standards
Certification is included in MTW Certifications of Compliance for HCV and local, non-traditional program. The public housing program is monitored through physical inspections performed by the Real Estate Assessment Center (REAC).
H. Public Comments
H.1 Please provide copy of all comments received by the public, Resident Advisory Board, and tenant associations.
Attached
Please attach a narrative describing the MTW agency's analysis of the comments and any decisions made based on these comments.
Attached
If applicable, was an additional public hearing held for an Agency-Specific Waiver and/or Safe Harbor waiver? N/A
If yes, please attach the comments received along with the MTW agency's description of how comments were considered.
I. Evaluations
I.1 Please list any ongoing and completed evaluations of the MTW agency's MTW policies, that the PHA is aware of, including the information requested in the table below. In the box "title and short description," please write the title of the evaluation and a brief description of the focus of the evaluation.
Does the PHA have an agency-sponsored evaluation? No
J. MTW Certifications of Compliance
J.1 The MTW agency must execute the MTW Certifications of Compliance form and submit as part of the MTW Supplement submission to HUD. Certification is provided below.
Appendices

Hardship Policy
The NSBHA has established a hardship policy to evaluate individual circumstances to address hardship exemption requests.

Applicable Family Situations
Qualifying hardships include the following:
1. The family has experienced a decrease in income because of changed circumstances including,
a. Involuntary loss or reduction of employment
b. Death in the family
c. Involuntary reduction in or loss of earnings or other assistance
2. The family has experienced an increase in expenses because of changed circumstances, for
a. Medical costs that exceed 25% or more of the family's current expense
b. Childcare costs that exceed 25% or more of the family's current expense
c. Involuntary loss of transportation, such as a serious car accident
d. Education
e. Similar items
f. Such other situations and factors determined by the NSBHA to be appropriate.
Process for Agency Review and Determination
When a client requests a hardship exemption from an MTW activity, the NSBHA will take the following actions:
1. Suspend the MTW activity beginning the next month after the request until the agency has determined if the request is warranted.
2. Determine whether a hardship exists within a reasonable time after the family request and whether it is temporary or long term.
3. The NSBHA will not evict the family during the 90‐day period beginning the month following the family's request for a hardship exemption.
4. If it is determined that a financial or other hardship exists and is TEMPORARY, the NSBHA will continue providing an exemption from the MTW activity at a reasonable level for up to 90 days. After that time, the NSBHA will reinstate the MTW activity from the beginning of the suspension. The NSBHA will offer the family a reasonable repayment agreement, on terms and conditions established by the NSBHA for the amount of back rent owed by the family.
5. If it is determined that a financial or other hardship exists and is LONG-TERM, the NSBHA will continue providing an exemption from the MTW activity at a reasonable level for a specified duration determined by the NSBHA. After that time, the NSBHA will reinstate the MTW activity from the beginning of the suspension. The NSBHA will offer the family a reasonable repayment agreement on terms and conditions established by the NSBHA for the amount of back rent owed by the family.
6. If it is determined that a financial or other hardship request did not meet hardship standards, the client must resume the MTW activity and collect any retroactive rent, if applicable, through a reasonable repayment agreement.
Resident and Participant Notification
The NSBHA will notify families of its Hardship Policy through its Administrative Plan, Admissions and Continued Occupancy Policy (ACOP), at intake, at recertification, and when a family is to be terminated due to an MTW activity.
Grievance Procedure
If a family's hardship request is denied, the family is permitted to go before the Hearing Officer for a second review.
Reasonable Accommodations
The NSBHA will address persons with handicaps requesting a reasonable accommodation under 24 CFR part 8 through the NSBHA's Reasonable Accommodations Policy and procedures.
Record Keeping
The NSBHA will keep clear records for hardship requests and determinations for three (3) years. These records are available for public review and inspection at the NSBHA's principal office during normal business hours and supplied to HUD if requested.