Introduction to the FSS Program and FSS Training

MODULE 1.3: Action Plan & Core Documents

This module describes the FSS Action Plan – a required document that summarizes the program’s policies and procedures – as well as resources that FSS coordinators and others will find useful in administering their programs.

The FSS Action Plan

Overview

In order to offer an FSS program, PHAs/owners must prepare an FSS Action Plan that describes the policies and procedures for the local operation of the program.

The FSS Action Plan describes:

  • Program size and characteristics of anticipated FSS participants
  • Services that the FSS program will offer
  • How the FSS program will be administered

The initial Action Plan must be submitted to HUD for approval. Changes to the Action Plan do not require HUD approval unless the PHA or owner proposes to make a policy change.

More information on the content of the FSS Action Plan is provided in the balance of this module.

Learn more about the Action Plan at 24 CFR §984.201.

Program Size and Characteristics

The FSS Action Plan must include the following information about potential FSS participants:

  • An estimate of the number of FSS-eligible families that can reasonably be expected to receive service based on available resources. Please note this is different from the minimum number of families that a PHA is funded to serve.
  • A description of the characteristics of the expected FSS families (including ethnic and racial data, program size) and the supportive service needs of the expected population.

New FSS programs may assume that FSS participants will be similar to the general population of the property.

The FSS Action Plan must also describe how FSS participants will be enrolled, including:

  • A description of the outreach efforts planned to recruit FSS participants from among eligible families and ensure that both minority and non-minority groups are aware of the FSS program.
  • A description of the incentives that the PHA or owner intends to offer eligible families to encourage participation in the FSS program, including FSS escrow accounts.

More information about the policies guiding the selection and enrollment of FSS participants can be found in Chapter 2.2: Outreach and Enrollment.

Services to be Provided through Partnerships

FSS Action Plans must describe:

  • The activities and supportive services to be provided by both public and private resources to FSS families.


And

  • A method for identifying family support needs.

PHAs and owners must certify in the FSS Action Plan that the services and activities scheduled to be provided under the FSS program have been coordinated with other service providers in the local community, including the Workforce Development Board through the Department of Labor and the Department of Health and Human Services. The Action Plan must further state that implementation will continue to be coordinated with these local public and private providers in order to avoid duplication of services. (See 24 CFR §984.201(d)(12).)

To ensure that FSS programs coordinate effectively with services in the community, FSS programs run by PHAs are required to establish a Program Coordinating Committee (PCC) comprised of representatives of different service  providers in the community. PHAs are required to consult with the PCC in developing their FSS Action Plans. More information on PCCs may be found in Chapter 6.

Note that multifamily FSS programs are not required to have a PCC though they have the option of doing so.

Policies and Program Implementation

The FSS Action Plan must include a schedule for program implementation and for filling all FSS slots with eligible FSS families.

The FSS Action Plan also must describe all FSS policies over which the PHA or owner has discretion, including:

  • Policies and procedures for selecting FSS participants, including whether the PHA or owner will offer a preference to prospective participants who are already enrolled in, or on the waiting list for, FSS-related service programs;
  • Policies related to the modification of goals in the Individual Training and Services Plan, including limits on modifications as participants approach graduation;
  • The circumstances in which an extension of the Contract of Participation may be granted;
  • Policies on the interim disbursement of escrow, including limitations on the use of the funds;
  • Policies for terminating or withholding supportive services or FSS participation for failure to comply with the Contract of Participation;
  • Policies regarding the re-admittance of previous FSS participants, including graduates and those who exited the program without graduating;
  • Actions to be taken if an FSS family underreports income or assets;
  • The grievance procedures for FSS families;
  • Policies for denying FSS participation to families owing money to the PHA or owner or to families previously terminated from the FSS program; and
  • Policies for providing an FSS selection preference for households exercising portability who had been enrolled in the FSS program at another PHA (if the receiving PHA elects to offer such a preference).

FSS Action Plan Approval

Before you can begin to enroll participants in your FSS program, HUD must approve your FSS Action Plan.

  To Get Started, Click to View a Selection from a Sample Action Plan from Nan McKay & Associates

  View This Sample Action Plan from Sioux City Housing Authority

  View This Sample Action Plan for the Connecticut Department of Housing developed by J. D’Amelia & Associates

Sample FSS Action Plans have been lightly edited before posting as example.

Core Documents and Resources for the FSS Program

In addition to this online training and the accompanying Administering an Effective Family Self-Sufficiency Program: A Guidebook Based on Evidence and Promising Practices, you should be familiar with a number of resources and core documents that describe the rules applicable to the FSS program.

HUD FSS Website

Many of the core documents for the FSS program can be found on HUD’s FSS Website or the HUD Exchange.

FSS program coordinators should thoroughly review all information on HUD’s FSS website which provides current information on grant opportunities and any updates to policies and procedures.

 Visit Website

FSS Chapter of HUD’s Housing Choice Voucher Guidebook

For a good basic overview of the FSS program regulations, see Chapter 23 of HUD’s Housing Choice Voucher (HCV) Guidebook. This Chapter describes the rules applicable to the HCV FSS program as of 2001 in plain language.

 View or Download

The FSS Program Regulations (24 CFR §984)

The FSS regulations specify the basic rules applicable to FSS programs administered by public housing agencies for the benefit of HCV holders and/or public housing residents.

 View Document

Waivers and Alternative Requirements for the FSS Program (79 FR 78100)

Upon the consolidation of the public housing and HCV FSS programs in 2014, HUD issued this brief notice that includes a number of provisions designed to reconcile rules that had previously applied differently to FSS participants in the HCV and public housing programs.

 View Document

Promoting Partnerships to Utilize Housing as a Platform for Improving Quality of Life (PIH Notice 2011-51)

This notice outlines suggested ways to forge partnerships with public and private agencies at the federal, state, and local levels to promote resident connections to health care, education, employment, and other social services in an effort to improve quality of life and provide a foundation for successful housing outcomes.

 View or Download

The Inventory Management System/PIH Information Center (IMS/PIC) Family Self-Sufficiency (FSS) Reporting and FSS Program Portability Provisions (PIH Notice 2016-08)

This Notice provides information on FSS reporting and portability including:

  • The circumstances under which PHAs must submit FSS Addendum reports to HUD.
  • Guidance and best practices on how to ensure accurate reporting to HUD about FSS.
  • Requirements for handling families on FSS who exercise portability or move from one PHA program to another.

 View or Download

Family Self-Sufficiency Program in Multifamily (HUD Notice H-2016-08)

This Notice implements the policies and procedures applicable to FSS programs administered in privately-owned HUD-assisted multifamily housing properties.

 View or Download

FSS Notices of Funding Availability (NOFAs)

PHAs that receive FSS program coordinator grants from HUD must adhere to the requirements specified in the FSS NOFA announcing that funding.

FSS NOFAs are published on HUD’s website and www.grants.gov when they are announced. You can sign up for notifications of NOFA publication on Grants.gov.

 View Document

FSS Grant Agreements

PHAs that receive FSS coordinator funding sign a grant agreement with HUD upon receipt of the funding. The grant agreement describes obligations the PHA must meet as a condition of receiving the grant.

View or Download

Contract of Participation (HUD Form-52650)

HUD has developed a form for the FSS Contract of Participation that specifies responsibilities of the PHA as well as the FSS participant.

 View or Download

HUD Privacy Protection Guidance for Third Parties (PIH Notice 2015-06)

This notice informs all public housing agencies (PHAs) about their responsibilities for safeguarding personally identifiable information (PII) required by HUD and preventing potential breaches of this sensitive data.

 View or Download

 

Please complete this quiz before you proceed to the next module. To take the quiz, use the arrow keys or click the correct answer choice. If you answer incorrectly, you will be able to try again until you select the correct response.
Scores will not be recorded.

1. Please select the correct statement:

A - The FSS Action Plan is an optional document that PHAs and owners may prepare at any time to guide the operation of their program.Incorrect.The FSS Action Plan is a required document that PHAs and owners must submit to HUD for approval before enrollment in the program can begin.B - The FSS Action Plan is a required document that PHAs and owners must submit to HUD for approval before enrollment in the program can begin.Correct!C - The FSS Action Plan is a required document that PHAs and owners may submit to HUD for approval at any point in the first year after program enrollment has started.Incorrect.PHAs and owners must submit the FSS Action Plan to HUD for approval before enrollment in the program can begin.D - The FSS Action Plan is a required document that PHAs must share with their Program Coordinating Committee, but it does not need to be submitted to HUD.Incorrect.PHAs are required to consult with their Program Coordinating Committee (PCC) in developing the FSS Action Plan, but they also must submit the FSS Action Plan to HUD for approval before enrollment in the program can begin. Multifamily owners are not required to have a PCC.

2. All of these statements except one are correct descriptions of the FSS Action Plan.  Which of these statements is False?

A - The FSS Action Plan describes how the organization will select and enroll FSS participants.Incorrect.This statement is True rather than False.  The FSS Action Plan must describe how the PHA or owner will conduct outreach to residents and to how to select and enroll FSS participants in the program.B - The FSS Action Plan describes the services and programs that will be made available to FSS participants.Incorrect.Nice try, but this statement is True rather than False.  The FSS Action Plan must describe the services and programs that will be made available to FSS participants so that they can achieve their individual goals.C - The FSS Action Plan is developed in consultation with the Program Coordinating Committee.Incorrect.Nice try, but this statement is True rather than False. PHAs that have a Program Coordinating Committee should develop their Action Plan in consultation with Committee members.D - The FSS Action Plan must be approved by HUD on an annual basis.Correct!Yes, this is the False statement. The FSS Action Plan needs to be approved by HUD before an organization can begin recruiting for the FSS program. Thereafter, FSS Action Plans only need to be re-submitted and approved by HUD if there are changes to program policies.

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