Notes from today’s meeting. And, yes, they area bit cryptic, but I was able to push “send” on the budget too! Thanks for all your great questions.
CSI Fair Housing and Property Management Roles, 10/1/12
Don’t need to be citizen to live in co-op, but need to have legal documents in place. Do need to have citizenship to receive federal subsidy. Some couples have one party receiving subsidy, but the other (sponsored to come to US by the first) doesn’t. Certification Department figures this out.
Don’t need to be married to live together.
Due to HUD contracts, members do need to have a mobility disability (even if non-apparent, such as balance).
Members/SCs cannot decorate for religious holidays, including simply decorating with colors (such as green and red or white and blue). If member has concern regarding this, refer them to liaison.
Members can vote to allow a bible study, but need to also accommodate time on co-op calendar for any other religious (official or not) study. Every new group is a vote. If the second group receives a “no vote” general membership, the liaison educates the members on Fair Housing laws. If necessary, all groups would be shut down.
Each co-op is a separate corporation, so each one would be named in the lawsuit, so their budget is charged. CSI does have on call a legal team, including Fair Housing attorneys ($450/hour).
Inadvertent discrimination = doing something for one that you don’t do for all. Don’t do a favor for one, if you aren’t absolutely certain that you can do it for all.
Email Anne Sackrison at Anne.Sackrison@csi.coop.org if you feel that referrals aren’t coming through to SC from President using the FCRC Flowchart. Copy (cc) Rachel and Sharon. This is especially important if president isn’t making uniform referrals.
If there is not FCRC chair, the President and Liaison assume the role. The Liaison has to make an initial visit, even if the President hasn’t received FCRC training and doesn’t attend. The Liaison could conduct the initial visit with a member of the FCRC Task Force (or another person determined by CSI). CSI will follow up on what to do if the Liaison hasn’t received FCRC training. SCs can accept a written referral from the President, even if the President has not attended FCRC training.
Fair Housing complaints that are outlined in the House Rules go to Liaison. If they are any other Fair Housing complaints, they need to put it in writing (dated and signed) to Cindy Lamb. This can be faxed from SC office, if the SC puts a written Consent to Release from the Member directly on top. They can use an Incident Report or right it long hand.
The Reasonable Accommodation process (like for tub cut out). Member must get forms and meet with Liaison and president. Many things can slow the process, such as doctor giving the form to the member to fill out themselves and turn in (form would be denied because doctor needs to fill out and mail directly back to corporate office because this is confidential medical information) or the time it takes to set up a meeting for a panel of 3 liaisons to review the request.
Reasonable Accommodations now come out of operating funds (they used to come out of residual receipts, but HUD has restricted use of the funds due to lack of funds). If there aren’t sufficient funds, the member’s request must be put on a wait list. Members can pay for it themselves. It becomes the property of the co-op. Sometimes members install accommodations that have to be restored to their original state (such as lifts). Members are not reimbursed if the funds become available. Tub cut outs are around $450. Roll-in showers may cost $10,000. Plumbing may not permit the ability to put in the accommodation.
Work Orders can be utilized for multiple types of disability access, including grab bars, raised toilet seat, equipment for the hearing impaired (like a strobe light smoke detector, but CSI cannot advertise it – it must be requested), or adjustable shower head. A Reasonable Accommodation form could be needed if it isn’t a standard raised toilet seat or grab bar. Direct these member questions to liaison if it isn’t an obvious work order. Some insurance companies cover durable medical equipment, such as a shower seat, with a doctor’s prescription. AASC is providing a webinar on Durable Medical Equipment Fraud on 10/17/12 at 2pm. You are invited to attend at Hazel Park Co-op (contact Alexa) or participate from your own desk (seek permission from Rachel to purchase webinar).
HUD requires $300 one-time security deposit (can be made in payments) any animal in apartment (must weigh less than 20 pounds). If member has a service animal, the deposit is waived and the animal may weigh more than 20 pounds.
Twice a year, the co-op fire marshals (with the additional support from the officers and/or coordinator) update the lists of members who may need additional support in the event of emergency. The emergency protocol is different by municipality depending on the regulations of the fire department. Some members may choose not to be on the list or not to pull the emergency pull cord because they don’t want the co-op to know (approximately 80% members choose to call 911 instead). Some municipalities/fire departments require their fire fighters to knock on everyone’s doors equally.
Slow down and take a breath. Inhale. Exhale. Things take a long time in the co-ops. Co-ops and CSI spend a lot of time creating and supporting the space for member empowerment (inclusive of members with fragile egos, in poor health, etc), because it is keeping them alive.
LAP (Language Assistance Plan) includes members of the co-op and surrounding community (liaison can use census data). If 5% or greater of a particular language is spoken at the co-op, then vital documents must be translated to that language (such as lease, HUD non-discriminatory form, house rules, bylaws). It is the responsibility of the co-op to pay a company to translate the documents (some standard ones are on the HUD website). These are for reference only. The member’s signature must by on the English version.
If member is applying to move into co-op has issues with the documentation needed to move into the co-op that was the result of domestic violence, co-op can permit entrance into co-op with appropriate proof. HUD Section 8 project based domestic violence regulations are for women only; CSI extends this to all people. If member is victim of domestic violence in the co-op, CSI can work with member to let them out of their lease in order to move.
Members need to talk with liaison and write up situations when they are discriminated against or harassed by other members. Members often chose not to report in writing because they are afraid. It is the responsibility of the liaison to educate members on the importance of documentation in writing.
By federal law, if a member has custody or temporary custody, of a child, they can live in the co-op.
If prospective member asks SC “what kind of people live here?”, SC cannot answer with any descriptions of demographics, “feel” of co-op or neighborhood, faith of bible study sessions.
Remember with fair housing, the SC can put both Hannan and the co-op in Fair Housing violation, if a mistake is made. Err on the side of saying “I don’t know the answer to that question” or refer them to the brochure at the front entrance, which has the 1-800 number for the waitlist.
All Co-ops have different original contracts based on the year it was built. Be aware of yours, because the co-op must abide by it (except when waivers are granted by HUD). This may explain some of the questions members or SCs have regarding the differences in how different co-ops operate. Refer questions to liaison.
Non-dependent children may not move in with member. They can stay as a registered guest for up to 30 days with family dependent on individual co-op policy (some have shorter stays).
PRACs are only eligible for budget based service coordinator funds renewed annually.
Co-ops may not change management companies to another company because CSI constructed the buildings.
Community clients. Remember client must be escorted to and from front door.
If client is prospective member is receiving assistance from SC with application documents: SC must obtain written client consent to release to CSI; SC escorts client back to leasing department (client must carry document back and turn it in themselves); remind prospective members that they must tell the whole truth on housing application (including all places they have lived, even if it was a shelter or couch at relative’s house, all criminal offenses including DUIs) – the Certification Department will double check on multiple databases. Sexual offenders may never live in HUD housing, but CSI must still process application as they would any other application.
If member doesn’t complete recertification paperwork in the prescribed amount of time, their apartment will go to market rate. They can come back down to their subsidized rate after paperwork has been completed and accepted.
Family has 14 days from the date of death to clear out apartment, or it goes to market rate. If member you are moving from one HUD-subsidized apartment to another HUD-subsidized apartment, they have 24 hours to move and turn in the keys to the first apartment (because federal government doesn’t permit double subsidy). If member incorrectly fills out certification documents and government catches the double-subsidy, member will be charged. This HUD debt will follow them wherever they move.
If co-op has newsletter created and published by the members, SCs cannot contribute articles, even if they are asked to by the members. The SC can be interviewed by a member and the member can write an article. Please be aware that a member may not write the article as you expected them to do!
Pontiac location opens in June, but will start having interested persons meetings in January. CSI will educate new members on how to write their own bylaws and house rules. Liaison will help new members with understanding fair housing and all of the applicable city, state, and federal policies that apply to their co-op.
Bylaws and house rules are living documents. Bylaws are written by the members and then they are reviewed by education department to assure compliance with relevant laws and policies. Bylaws changes are posted for a set period of time (see yours) and must be approved by 2/3 (depending on the bylaws of that co-op, that could be 2/3 of the full membership or 2/3 of members present) vote. Then national board of directors (BOD; comprised of members from MI, CA, MA and MD) votes to approve. Each member will receive a printed version of the document within 30 days (may differ by co-op) with a letter attached that includes language from HUD that requires they sign that they have received and read the changes or they will be evicted (language is required by HUD, not CSI). This applies for bylaws, house rules (house rules don’t need to be approved by national BOD), or pet rules changes. If a co-op adopts a new rule into their bylaws in order to comply with the national BOD policies, the bylaws don’t need to go back to the BOD for approval unless they alter (expand) the policy.
If a general or council meeting becomes too heated with shouting, the liaison or other CSI staff person can shut the meeting down.
Interpretation of CSI documents. Refer members back to CSI liaison. If liaison isn’t responsive, please contact Rachel and CSI will work on getting a response.
Co-ops cannot charge more than the actual cost of replacing the key or fob. Members are permitted to make copies of their apartment keys to share with family, friends or other members. Members are not permitted to share their key fob with anyone else. Sharing a key fob is a lease violation. Members may report this on an incident report to the president or liaison.
SCs must report lease violations too. Fax it to your liaison or share with liaison at monthly meeting. Sharon will work on revising a service coordinator version of the incident report to use.
Bullying. SC should report this as soon as it is witnessed using the new service coordinator incident report. If it is very serious and emergent, call the police. Liaison should be giving members “micro mini” trainings on this and other important topics at least once a year, or more often if needed.
Closed Council after a minimum of 3 separate incident reports (or 1 if it is a single strike offense). First meeting. Does not include member. Usually a warning letter results. Liaison asks council how they want it worded and give advice. President signs letter and it is given to member in mail and under door within 72 hours of meeting. If it includes a corrective action, it is up to the liaison and president to follow up. It may also include a referral to the FCRC with follow up “check ins” or apartment inspections.
If the member receives additional incident reports, there is a second meeting. Usually the member is invited. It may result in a similar protocol for as the first meeting.
There is no set amount of times the member comes to closed council, but council is not permitted to apply differential applications of warning letters or eviction for similar situations for two different members of the co-op.
If the decision is to evict, the member receives 30 day notice to evict. Hand delivered and through the US Mail. The letter of eviction includes who the member should contact (CSI’s attorney and phone number). A due process meeting will be set up with the attorney and president either at the co-op or attorney’s office. The member can bring their own lawyer or family member. The member may negotiate for a longer period of time to move out of the co-op. Occasionally, the member may negotiate to remain in co-op on probation. Member cannot talk with the SC, liaison or CSI staff about the eviction. SC can continue to work with members on non-eviction matters, including assistance with finding alternative housing. The SC cannot advocate with CSI on status of eviction. If the member moves out prior to eviction, the eviction is not reported by CSI. If the person doesn’t move out after the 30 days, CSI’s attorney sets the court date with the court in that area. This may take months in the City of Detroit. Hence, CSI cannot share date of move out with SC. They do not know themselves. There is a separate process for non-payment of rent, which is processed by the liaison. The council is responsible for all issues of material non-compliance.
Prior to inspection, liaison gives 30 day notice to all members regarding the upcoming inspection. Inspections are biannual. CSI is not supposed to give passes to good volunteers. Equal treatment needs to be given to all. Members have two opportunities to pass inspection (with two weeks in between to correct the problems). Members who don’t pass go to closed council. Council determines the corrective action plan. It may vary by council, but may include a set length of time to correct the violation or specific tasks that need to be completed.
Inspectors (members) go in teams of two with check sheet (Sharon will provide check sheet for SCs and also ask liaisons at their staff meeting next week if the SCs could be invited to one of the biannual trainings to learn about the process so that they know they know about the process to help members who are clients prepare for inspection (most notably for members who have a tendency to hoard or clutter). They must attend biannual trainings to be on inspection team. They are asked not to inspect their friend’s (or foe’s) apartment. The liaison must be present in co-op at time of inspection. The inspectors can talk with the liaison regarding particular inspection that day, particularly if they feel that it may result in an eventual FCRC referral.
Monthly meeting tips:
– Sharon will talk with liaisons again at their staff meeting regarding the importance of monthly meetings. Liaisons are required to set the date based on a time that the liaison knows the SCs are available to attend.
– Suggest regular meeting date.
– Required attendees (or else suggest that the liaison reschedule) include the President, FCRC Chair, and Liaison. Recommended additional attendees include the VP and Education Chair.
– Suggest setting monthly SC well-being meetings
– CSI updates SC on changes in CSI policies and procedures (bylaws, house rules, pet rules, etc)
– SC can ask for clarification of rules and regulations
– Ask questions, especially if members appear to be interpreting the rules differently than in manual.
– If liaison doesn’t attend monthly meeting, SCs are requested to email Anne Sackrison and cc Rachel and Sharon. This is a very important monthly meeting.
– SC can ask FCRC or Education Chair if they would be interested in announcing an upcoming well-being meeting or other important social service dates (such as Medicare open enrollment). This is your opportunity to support their roles on their committee. This is the place where you work with the FCRC and Educational Chair to learn what they find are the interest areas and needs of the members, any recommended speakers or organizations, and ideas for educational workshops.
– SCs should bring updates of their resource directories and extra resource/educational materials for the FCRC to make available to members 24/7 in an accessible place.
– The meeting should be held in a public place, such as the library or lounge, so that members know that no confidential material is being exchanged.
Each Co-op has a star phone that is set up in a community room so that members can listen to Board Meetings.
CSI has a Congress. Each co-op elects delegates to congress. They may elect one delegate for every 50 apartments in their co-op, but every co-op has at least two. Congress meets 3 times per year and is link between the Board of Directors and the co-ops.
CSI will not be providing SCs with notification of recertification timelines. Most members have been working consistently in preparation for recertification time (they receive consistent communications from CSI). There shouldn’t be an inundation. CSI wants to make sure that members continue to feel they can complete the documentation themselves or with the assistance of the Certification Department. Certification specialists will work with members and help educate the members on how to submit their documentation in a manner that achieves the most favorable rent rates for members.
