Professional Documents
Culture Documents
Policy and Procedure Development
Policy and Procedure Development
Introduction
The objectives of this session are to:
Distinguish between mandatory and discretionary policy requirements Analyze language in regulations to determine what decisions have to be made and included in written policy and/or procedures to ensure consistency in rent determinations
Introduction
The quality control study published by HUD PD&R Office says:
Weaknesses in PHA policies and procedures contribute to rent errors. Areas of PHA discretion enable PHAs to adapt the program to local conditions [good!] BUT also create the potential for confusion and inconsistency [not so good].
Introduction
The challenges for PHAs are to:
Understand what is mandatory and what is discretionary
Introduction
The challenges for PHAs are to:
Develop procedures that translate the mandatory and discretionary policies into action
Communicate (and train) policies and procedures to ensure consistency Monitor policies and procedures to ensure they are being complied with by staff
Introduction
To help you meet your challenges, well:
Focus on distinction between mandatory vs. discretionary policies Show you how lack of policies and procedures may be contributing to errors Help you think through how your agency handles discretionary items Suggest ways for improving your policies and procedures
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Daily guidance to staff in the performance of routine activities Make decisions more transparent to staff and the public Are more defensible than unwritten policies when challenged Ensure that everyone does things the same way (consistency, fairness, minimize litigation)
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If there is no policy or procedure and practice is inconsistent, the reviewer will note this as a finding
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Current notices
Most PIH notices have an expiration date PIH notices may be extended or reinstated
HUD Handbooks
Forms required by HUD regulations (such as 50058) OGC Opinions or Rulings
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Notices that have expired (unless changed by mandatory reference) Handbooks that have expired (unless changed by mandatory reference) Recommendations from individual HUD staff not based on regulatory requirements
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HUD Regulations
Child Care Example: Two HUD regulations address this deduction (page 2-9)
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Decision Points
To develop policies and procedures for implementing the child care expense deduction, your PHA must first identify the decision points in the HUD regulations and guidance.
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Reasonable means reasonable for the care being provided. (in-home vs. day care center or elsewhere) Remember: Families may choose the type of care to be provided.
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Policies state:
See Translating Requirements into Policies and Procedures Example in course materials Page 2-13
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Developing Procedures
There is no HUD-required form or format, but procedures must be consistent with HUD requirements. PHAs can develop procedures based upon the specific work flow at their own agencies.
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Developing Procedures
Elements of a good procedure:
Explanation of (or citation for) policy Task(s) that need to be done Staff who is/are responsible Time frames that must be observed Forms and/or systems that will be used Approvals that are necessary Instructions for decisions and calculations that must be made by staff
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Developing Procedures
See Excerpt from ABC PHA Minimum Rent Procedure (page 2-19)
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Remember that Guidebooks are not mandatory but are helpful references for acceptable policy language Establish local policies and procedures Train staff Monitor staff for consistency When questions arise, make decisions and add to already-established policy and procedures
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Learning Objective
Develop well-conceived policies and effective procedures, taking into account mandatory requirements and prohibitions and areas of policy discretion
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