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Program Obligations and Termination
While HUD does not identify any mandatory family obligations under
the program, PHAs can choose to establish such obligations. The
final Merger Rule requires that the PHA inform WtW families, both
orally and in writing, of any family obligations under the program
and advise them that willful and persistent failure to meet these
obligations is grounds for PHA denial of admission or termination
of assistance. PHAs may opt, but are not required, to terminate
assistance of WtW families based on their failure to meet WtW family
obligations.
Within these general parameters, PHAs have the flexibility to design
family obligations and establish termination policies under the
WtW Voucher Program that best support the local goals and objectives
of the program. When designing a family obligations policy, PHAs
and their partners need to balance the following considerations:
- Target populations may have difficulties in obtaining or retaining
employment and are likely to cycle in and out of jobs; and
- Families need to take the work obligations seriously. If they
willfully or persistently fail to meet these obligations, they
should be terminated.
The challenge, then, is to develop a policy that is forgiving but
also enables the PHA to identify families who are abusing the program
or in danger of abusing the program. Termination should be a measure
of last-resort.
As in the regular voucher program, the PHA must communicate any
denial or termination of assistance to the family in writing. In
addition, the PHA must give the family the opportunity for an informal
review or hearing before the PHA denies admission or terminates
assistance.
PHAs and their partners also may determine that a WtW family no
longer needs the supportive services associated with the WtW voucher
program. In such a case, the family must continue to be assisted
under the regular voucher program since time-limited assistance
is prohibited.
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