Voluntary Compliance Agreement Update

VCA: Construction Activities at Administrative Offices What we MUST do: 1. Make offices at 1441 West 25 th Street accessible to persons with disabilities 2. Make Stokes Mall accessible to persons with disabilities 3. Independently certify accessibility to HUD What we HAVE done: 1. Offices at 1441 West 25 th Street are now accessible 2. Stokes Mall is now accessible 3. Accessibility certified in June and August 2009

VCA: Construction Activities at Properties What we MUST do: 1. Create 482 UFAS- accessible units over next 7 years 2. Make the sites at these properties accessible also 3. Independently certify accessibility to HUD What we HAVE done: 1. To date, we have 101 units completed as UFAS- accessible. Working on an additional 97 units for All site work complete for year 2009 properties; currently working on year 2010 properties units certified to HUD; year 2010 units will be certified toward year end

VCA: Policy Changes Transfer Policy UFAS units are offered to qualified residents and applicants in the following order: 1. To a current resident with disabilities in the same development in order of date and time of transfer request 2. To a current resident with disabilities in another development or AMP in order of date and time of transfer request 3. To an eligible, qualified applicant with disabilities on the waiting list in order of date and time of application 4. To an eligible, qualified applicant on the waiting list who does not require the features of the UFAS unit. BUT, if they accept this unit, they have to sign a lease addendum agreeing to relocate to a non-UFAS unit, at CMHA’s expense, if a resident or qualified applicant needs the unit

VCA: Policy Changes (continued) Pet Policy Assistance animals that are needed as a reasonable accommodation for persons with disabilities are NOT considered pets There is NO deposit required for an assistance animal Assistance animals are NOT required to have a training certificate CMHA must allow a person with a disability to have an assistance animal unless there is evidence that the animal poses a direct safety threat, would cause physical property damage, or would alter the nature of our services. Assistance animals are still subject to other sections of the pet policy, including pet behavior, sanitation, registration, etc. Assistance animals MUST be approved through the reasonable accommodation process

VCA: Policy Changes (continued) Effective Communication Policy This is a new policy for the 2008 ACOP (Section 13) CMHA will ensure effective communication with applicants, residents, employees, and members of the public CMHA will furnish appropriate auxiliary aids and services to allow individuals with disabilities to participate in our programs Upon request, CMHA will provide forms and information in alternate formats to provide effective communication Auxiliary aids and services should be requested via reasonable accommodation forms (or via non-written format if necessary)

VCA: Policy Changes (continued) Reasonable Accommodation Policy This is a new policy for the 2008 ACOP (Section 14) Reasonable accommodations are changes or adaptations in policies or procedures that provide a qualified person with a disability the opportunity to participate in our programs Examples include: Transferring a resident from a unit that cannot be made accessible to one that is Making a sign language interpreter available to a qualified applicant or resident with a hearing impairment Lowering a peephole on a resident’s unit door CMHA will provide reasonable accommodations to qualified individuals consistent with our policy and procedures

VCA: Policy Changes (continued) Revised Preliminary Application Application includes the contact information for the Section 504/ADA Coordinator (Dorivette Nolan) Asks applicants with disabilities to specify if they need a unit with accessible features Asks applicants with disabilities to specify if they require reasonable accommodations in their housing and/or during the application process, consistent with CMHA’s Reasonable Accommodation Policy

VCA: Policy Changes (continued) Lease Addendum for UFAS-Accessible Units Addendum requires a resident without a disability who occupies a UFAS-accessible unit (or one with accessible features) to relocate to a vacant, non- accessible unit, at our expense, within 30 days’ notice by CMHA that either a qualified applicant or resident with a disability requires the features of the unit Addendum must be signed at lease execution and at each recertification for as long as the resident without a disability occupies the accessible unit

VCA: Operational Changes Changes to Elite (Applicants and Current Residents) Added ability to track applicant’s/resident’s “ADA Requirements” (hearing impaired, sight impaired, UFAS mobility, or other) Added ability to update applicant’s/resident’s characteristics to track specific needs (i.e., bed and bath on first floor, separate bedroom, grab bars, etc.) Added notifications to alert users that the applicant/resident requested a reasonable accommodation

VCA: Operational Changes (continued) Reasonable Accommodation Procedures CMHA developed procedures to implement new Reasonable Accommodation Policy, including various forms and an Intranet-based Reasonable Accommodation Log Changes to Application/Recertification Process Distribute a “VCA refresher notice” to each resident at recertification and each applicant at eligibility briefing session Offer copy of Transfer, Pet, Reasonable Accommodation, and Effective Communication policies to each resident at recertification and each applicant at eligibility briefing session (they don’t have to take it, but have the option to request at any time and we must provide it)

VCA: Operational Changes (continued) Revise printed materials to include the following effective communication language: “CMHA provides reasonable accommodations to persons with disabilities. If you need an accommodation, including auxiliary aids and/or services, please contact CMHA’s Section 504/ADA Coordinator at (voice) or (Ohio Relay Service)” HCVP has slightly different language on their printed materials Development of a UFAS construction tracking website on Intranet

VCA: Training Effective communication with persons with disabilities training (August-September 2008) Fair Housing Disability Rights workshop (January 2009) UFAS Accessibility Maintenance/Contractor training (March 2009) Elite/Reasonable Accommodation Log training (April 2009) Ongoing training throughout duration of VCA New employees Annual 3-hour refresher course

VCA: Notification Employee Notices “Terms of the VCA” letter distributed in August- September 2008 Also distributed to new employees at orientation “Policy Notification” letter distributed in April 2009 Also distributed to new employees at orientation Resident Notices Distributed VCA to LAC’s in August 2008 Mailed VCA/policy notification letter to all residents in March 2009 Distribute “VCA refresher notice” at each recertification 4 policies posted in all management offices and application office

VCA: Applicability to Private Management Agents The provisions of the VCA are applicable to properties managed by private management agents (Cleveland Housing Network, Tremont Pointe, Union Court, Detroit Shoreway) Management agents are required to convert a certain number of their public housing units to UFAS-accessible units These management agents had to revise their policies and procedures to comply with VCA requirements Each management agent has its own Section 504/ADA Coordinator to coordinate reasonable accommodation requests for their properties

VCA: Reporting Requirements Quarterly/Semi-Annual Reporting: UFAS-accessible unit production Transfer/occupancy statistics Reasonable accommodation requests “Money Follows the Person” statistics Staffing and training Physical improvement plans Policies and remediation plans Ongoing monitoring of policies

Money Follows the Person Ohio HOME Choice Program In May 2009, the Cuyahoga Metropolitan Housing Authority committed 25 vouchers from the Housing Choice Voucher Program (HCVP) for use with Ohio’s HOME Choice Program (Federally known as Money Follows the Person). To qualify for HOME Choice, a person must be elderly or have a disability, must have been living in a long-term care facility using Medicaid for three months or more and be able to move back into the community.

Three-Way Partnership The HCVP coordinates with staff from the Ohio Department of Jobs and Family Services (ODJFS), who is the recipient of the federal funds in Ohio. The ODJFS works with local Transition Coordinators (TC) to assist clients of HOME Choice who want to transition back into the community.

Three-Way Partnership Objectives: To provide housing assistance to older adults and persons with disabilities who wish to return to the community from an institutional setting To work effectively with ODJFS and local TC to assist clients of HOME Choice who want to transition back into independent living

Three-Way Partnership Responsibilities: ODJFS Refer clients to the HCVP Hold bi-weekly conference calls with HCVP to review clients status Serve as the liaison between the HCVP and TC Subcontracts the discharge planning process to designated TC’s in each local area

Three-Way Partnership Responsibilities cont.: ODJFS Provides supplemental services for the clients which includes: $2,000 for goods and services (i.e.: 1 st month rent, security deposit, utilities, phone, furniture, travel, etc.) Community Support Coach Independent Living Specialist Assistive technology devices etc.

Three-Way Partnership Responsibilities cont.: ODJFS Each HOME Choice client is assessed and provided a Ohio Medicaid waiver (based off of eligibility criteria). The Waiver provides home care which includes : Case Manager over the Service Plan Personal Care Aide (to assist with daily living tasks) Nursing care Home Modification funds (ramps, accessible bathrooms, kitchens)

Three-Way Partnership Responsibilities cont.: TC Identify and refer prospects to ODJFS Assist the client with gathering required documentation for admission to HCVP Attend all meetings scheduled by HCVP Assist the client in locating an appropriate, accessible unit Assist the client with the coordination of their move (furniture, utilities, phone, groceries, medicine, etc) Assist the client with eliminating any barriers they may experience

Three-Way Partnership Responsibilities cont: HCVP Conduct eligibility interviews at long-term facility with TC present Conduct voucher briefing and issue voucher at long-term facility Inspect unit to determine compliance with HQS and ensure that rent is reasonable Execute HAP contract with landlord in order to pay subsidy on behalf of the client

Status of 25 Vouchers 12 clients housed 6 clients searching for unit

Obstacles: One of the major obstacles initially was clearly educating the TC’s on the rules of the HCVP. Specifically, the required timelines relative to qualifying applicants, the term of voucher and executing HAP contracts Because the clients are coming from a long-term facility, the TC’s are having a difficult time collecting the required documentation needed for admission into the HCVP in a timely manner

Obstacles cont.: After the voucher has been issued, TC’s are experiencing difficulty with 2 major issues in finding housing within the 120 day term of the voucher : Necessary design accommodations to meet the clients’ needs Housing is being denied frequently based off of clients’ background checks after HCVP have approved the voucher

Obstacles cont.: Receiving referrals timely in order to utilize all of the 25 vouchers allocated to Home Choice. TC’s are experiencing the following: Mental health clients have been difficult to refer to HCVP because of their criminal background Locating transient clients within the nursing home system, transferring from one nursing home, to another nursing home or being discharged from the nursing home