BETHLEHEM RETIREMENT VILLAGE TENANT SELECTION PLAN

Bethlehem Retirement Village is a non-profit, Section 202/8 HUD-subsidized apartment community in Flourtown, Pennsylvania sponsored and managed by the Sisters of St. Joseph of Chestnut Hill, Pennsylvania. It is a four-story property consisting of 76 one-bedroom and 24 efficiency apartments. Five of the apartments are handicap-accessible.

It is the policy of this site to promote equal opportunity and nondiscrimination in compliance with all federal, state, and local laws and regulations pertaining to nondiscrimination, equal opportunity, and affirmative fair housing marketing. In carrying out this Tenant Selection Plan, there will be no discrimination on the basis of race, color, creed, religion, national origin, citizenship, ancestry, sex, sexual orientation, gender identity, familial status, marital status, disability, or other basis prohibited by local, state, or federal law in any aspect of tenant selection or matters related to continued occupancy.

Bethlehem Village operates in full compliance with HUD’s Equal Access Rule and Title VI of the Civil Rights Act of 1964, The Fair Housing ACT/Title VIII of the Civil Rights Act of 1968, and Section 504 of the Rehabilitation Act of 1973 and will make reasonable adjustments to rules, policies, and structures in order to enable an applicant with a disability to have an equal opportunity to use and enjoy the unit and common areas.

Bethlehem Village will verify that all prospective residents meet eligibility requirements governing Section 8 of the United States Housing Act of 1937 and Section 202 of the Housing Act of 1959.

Age Requirements

The head of the household, co-head, or spouse must be at least 62 years of age.

Non-elderly handicapped applicants are eligible only for an accessible unit and if the applicant requires the accessibility features of the unit.

Income Requirements

Bethlehem Village only accepts applications from those meeting the very low income and extremely low income limits determined by the Department of Housing and Urban Development. Any applicant exceeding the HUD income limits at the time of application will be rejected.

Exact income limits are subject to change as mandated by HUD.

Asset Limits

The owner must deny admission of an applicant family for the following:

  • Net family assets that exceed $100,000.00 (adjusted annually for inflation); and/or
  • The family has a present ownership interest in, and a legal right to reside in, and the effective legal authority to sell the real property (based on laws of the state or locality in which the property is located) that is suitable for occupancy by the family as a residence.

Citizenship Requirements  

Assistance in subsidized housing is restricted to U.S. citizens or nationals and noncitizens who have eligible immigration status as determined by HUD (HUD 4350.3 3-12).

All family members, regardless of age, must declare their citizenship or immigration status. US citizens must sign a declaration of citizenship. Noncitizens age 62 or older must sign a declaration of eligible immigration status and provide a proof of age document.

Social Security Number Requirements

Applicants and tenants must disclose and provide documentation of the complete and accurate Social Security Number (SSN) assigned to each household member. While applicants do not need to provide verification of a Social Security number for household members in order to be placed on the waiting list, they must do so before they can be housed.

If all household members have not disclosed and/or provided verification of their SSNs at the time a unit becomes available, the next eligible applicant must be offered the available unit.

If the Management determines that applicants are otherwise eligible to participate in a program, they may retain their place on the waiting list for the 90-day period from the date they were first offered an available unit but cannot become tenants until they can provide the documentation.

After 90 days, if applicants have been unable to supply the required SSN and verification documentation, they will be deemed ineligible and removed from the waiting list.

If a child under the age of 6 years is added to the applicant household within the 6-month period prior to the household’s date of admission, the applicant may become a tenant, so long as the SSN documentation required is provided to management within 90 calendar days from the effective date of the Move-In Certification. Management will grant an extension of one additional 90-day period if they determine that, at their discretion, the applicant’s failure to comply was due to circumstances that could not reasonably have been foreseen and were outside the control of the assistance applicant. e.g. delayed processing of the application by the SSA Office, natural disaster, death in the family etc..

The Social Security number requirements do not apply to individuals who do not contend eligible immigration status. When applicants and residents are required to declare their citizenship status, the existing regulations pertaining to proration of assistance or screening for mixed families must continue to be followed.

Individuals age 62 or older as of January 31, 2010, whose initial determination of eligibility was begun before January 31, 2010 are exempt from providing Social Security verification.

Adequate Social Security Documentation

  • Social Security card issued by the Social Security Administration
  • original Social Security card or original document issued by a federal or state government agency which contains the name, SSN, and other identifying information of the individual
  • driver’s license with Social Security number
  • identification card with Social Security number issued by a federal, state, or local agency, a medical insurance provider, or an employer or trade union
  • earning statements or payroll stubs, bank statement, Form 1099, benefit award letter, retirement benefit letter, life insurance policy, or court records that include Social Security number, name, and other identifying information of the individual

There are five handicap-accessible apartments in the building (five percent of total units). To be eligible for these apartments, applicants must be disabled and require the accessibility features of the apartment. As applicants near the top of the list and in preparation for their eligibility interview, their healthcare provider will need to complete a third-party verification form attesting to the applicant’s status as a disabled person who could benefit from an accessible apartment.

This does not require disclosure of medical information about an applicant’s disability.

Eligible applicants under the age of 62 who are on the waiting list for one of the five accessible units but who wish to leave that list and request a standard apartment may do so once they reach the age of 62. However, they will be required to submit a new application and will be placed at the bottom of the waiting list for a standard apartment.

For a more detailed description of the accessibility features of both traditional and accessible apartments, please see our application packet or call the office at 215-233-0998.

Section 8 assistance shall not be provided to any individual who is enrolled as either a part-time or full-time student at an institution of higher education for the purpose of obtaining a degree, certificate, or other program leading to a recognized educational credential unless one or more of the following exceptions exist:

  • The student is 24 years of age or older.
  • The student is married.
  • The student is a veteran of the United States Military.
  • The student has a dependent child.
  • The student is a person with disabilities, as such term is defined in 3(b)(3)(E) of the United States Housing Act of 1937 (42 U.S.C. 1437a(b)(3)(E)) and was receiving Section 8 assistance as of November 30, 2005.
  • The student is living with his or her parents who are receiving Section 8 assistance.
  • The student is individually eligible to receive Section 8 assistance and has parents (the parents individually or jointly) who are income eligible to receive Section 8 assistance. 
  • The student is eligible independent of his or her parents, where the income of the parents is not relevant. For the student to be eligible independent of his or her parents, where the income of the parents is not relevant, the student must demonstrate the absence of, or his or her independence from, parents. Management will use the following in determining a student’s independence from parents. The student must meet all (1-4 below) of the following criteria to be eligible for Section 8 assistance:
    • The student must be of legal contract age under state law.
    • The student must have established a household separate from parents or legal guardians for at least one year prior to application for occupancy, OR, meet the U.S. Department of Education’s definition of an independent student. In the Federal Register (Vol. 81, No. 183) published September 21, 2016, HUD reclassified the definition of independent student to include vulnerable youth and to align with the U.S. Department of Education’s definition as follows:
      • The individual is 24 years of age or older by December 31 of the   award year.
      • The individual is an orphan, is in foster care or has been a ward of the court at any time since the individual was 13 years of age or older.
      • The individual is, or was, immediately prior to attaining the age of majority, an emancipated minor or in legal guardianship as determined by a court of competent jurisdiction in the individual’s state of legal residence.
      • The individual is a veteran of the Armed Forces of the United States (as defined in subsection (c)(1) of HEA) or is currently serving on active duty in the Armed Forces for other than training purposes.
      • The individual is a graduate or professional student.
      • The individual is a married individual.
      • The individual has legal dependents other than a spouse.
      • The individual has been verified during the school year in which the application is submitted as either an unaccompanied youth who is a homeless child or youth (as such terms are defined in section 725 of the McKinney-Vento Homeless Assistance Act) (42 U.S.C. 11431 et seq.), or as unaccompanied, at risk of homelessness, and self-supporting by selected agencies or personnel as noted in Federal Register / Vol. 81, No. 183 / September 21, 2016.
      • The individual is a student for whom a financial aid administrator makes a documented determination of independence by reason of other unusual circumstances.
    • The student cannot be claimed as a dependent by parents or legal guardians pursuant to IRS regulations.
    • The student can obtain a certification of the amount of financial assistance that will be provided by parents, signed by the individual providing the support. This certification is required even if no assistance will be provided.

In addition to eligibility for housing, management will also determine a student’s eligibility for Section 8 assistance at annual recertification, initial certification, and at the time of an interim recertification if one of the family composition changes reported is that a household member is enrolled as a student.

Any financial assistance a student receives (1) under the Higher Education Act of 1965, (2) from private sources, or (3) from an institution of higher education that is in excess of amounts received for tuition is included in annual income, except if the student is over the age of 23 with dependent children or if the student is living with his or her parents who are receiving Section 8 assistance. If an ineligible student is a member of an existing household receiving Section 8 assistance, the assistance for the household will not be prorated but will be terminated in accordance with the guidance in paragraph 8-6 A

Receiving Applications

Applications are received by mail and in-person. If eligible, applicants are placed on the waiting list by the date and time the application was received and are notified by mail that they have been placed on the list.

Denial of Admission

Admission is denied to a household for the following reasons:

  • The household contains a member(s) who has been evicted in the past three years from a federally assisted site for drug-related criminal activity. The two exceptions to this provision include that the evicted household member has successfully completed an approved, supervised drug rehabilitation program, or the circumstances of the eviction no longer exist (e.g. the household member no longer resides with the applicant household).
  • The household includes a member is currently engaged in illegal use of drugs or the owner has reasonable cause to believe that a household member’s illegal use or pattern of illegal use of a drug may interfere with the health, safety, and right to peaceful enjoyment of the property by residents. The use of marijuana, (medical and/or recreational) is considered to be the use of an illegal drug.
  • Any household member is subject to a state sex offender lifetime registration requirement.
  • There is reasonable cause to believe that any household member’s behavior, from abuse or pattern of abuse of alcohol, may interfere with the health, safety, and right to peaceful    enjoyment by other residents. The screening standards will be based on behavior, not the condition of alcoholism or alcohol abuse.
  • There is reasonable cause to believe that the any household member’s behavior may threaten the health, safety, and right to peaceful enjoyment of the property by other residents or the health, and safety of the owner, employees, contractors, subcontractors or agents of the owner.
  • Any household member has committed fraud in connection with any Federal Housing Assistance program.

If not eligible, the applicant will be notified by mail. The reason for rejection will be detailed and an opportunity for appeal will be given. A written appeal must be received in the management office within 14 days from the date of rejection. Appeals will be heard by the Management Agent of St. Joseph Housing Corporation.

If the applicant is in need of reasonable accommodations to attend this appeal meeting, these accommodations will be provided. If the applicant wishes to appeal the Management Agent’s decision, information on how they may contact the local HUD office will be provided.

All rejected applicants will receive a copy of the HUD Notice of Occupancy Rights under the Violence Against Women Act (VAWA) with the rejection letter.

Applicants who are rejected may re-apply only if twelve months have passed since the application was rejected, and the household circumstances have changed so as to remove the original reason(s) for which the application was rejected.

Keeping Contact Information Current

Applicants will be removed from the waiting list if mail sent to their address is returned as undeliverable. Prospective tenants must contact the Bethlehem Village Office by letter, phone, or in person whenever their phone contact information or address changes.

Annual Letter of Interest

The Village Management will mail applicants a letter once a year in early January to confirm that they are still interested in remaining on the waiting list.

If applicants do not respond to the letter within 21 days of when it was mailed, the Management will reach out a second time by phone. If there is no reply to the letter or phone call, the applicant will be removed from the waiting list. If applicants anticipate being away in January, they should contact the office in advance by letter, phone, or in person to confirm their interest in remaining on the list.

Contact in Chronological Order

AsAs vacancies arise, applicants are contacted in chronological order by date and time of application.

Skipping over Applicants

Income-Based Selection: Bethlehem Village will make at least 40 percent of the assisted units that become available in each fiscal year available to families whose income is determined to be extremely low at the time of admission in compliance with HUD requirements.

If the percentage of extremely low-income applicants is anticipated to fall below 40%, the Management will skip over very low-income applicants on the list and select from extremely low-income applicants in chronological order until the 40% target has been achieved. Very low-income applicants will not lose their place on the waiting list, and once the target has been achieved, they will be contacted in chronological order when apartments become available.

Refusing an Apartment: When an apartment becomes available, applicants are contacted for an interview to determine eligibility. If they choose not to move forward at that time, it is considered a “first refusal.” They retain their place on the waiting list but are not contacted again for a period of one year. If, after a year, they are contacted about another apartment and choose not to move forward a second time, they are removed from the waiting list. If desired, they can submit a new application but will start once again at the bottom of the waiting list.

Eligibility Interviews

As applicants near the top of the waiting list, they will be notified of their position on the list and asked to make an appointment for an interview, at which time information will be updated and the third-party verification process begun.

All applicants and live-in aids will be subject to a criminal background screening. Sex Offender screening will be conducted each year at the time of the resident’s annual recertification.

References from present and previous landlords for a minimum of three (3) years prior to application will be considered. An applicant may be rejected if these reports document the following:

  • consistent failure to make rental payments
  • responsibility for disturbing the safety, security, and right of peaceful enjoyment of other tenants
  • instances of criminal activity, such as illegal gambling, prostitution, or manufacture, sale, or use of illegal drugs
  • allowing persons not on the lease to reside on the premises or any other serious violations of the lease
  • threats of violence to the landlord or neighbors
  • damage to property beyond normal wear and tear
  • poor housekeeping exhibited by habits which could be detrimental to the well-being of other residents, such as poor care of appliances, plumbing fixtures, etc.; poor health habits, evidence of negligent care of the property, physical abuse of the facilities, any evidence of conduct which could be detrimental to the property
    NOTE:  Poor quality or shabby furnishings are not a basis for rejection.    

Enterprise Income Verification (EIV)

The EIV system will be done as part of any new applicant screening criteria. EIV is a web-based computer system that contains employment and income information of individuals who participate in HUD rental assistance programs. The information obtained from EIV includes:

  • confirmation of name, date of birth, and Social Security number on file with the Social Security Administration
  • verification of reported income sources and amounts
  • confirmation of participation in only one HUD rental assistance program
  • Prior to move-in, the EIV search will be used to see if each applicant and applicant household member is receiving assistance at another location (Existing Tenant Search).

The waiting list may be closed if Bethlehem Village determines that the expected time from application to move-in is greater than seven years. Management will advise potential applicants of the closure and will also publish a notice stating the reasons in the local newspapers.

When management agrees to accept applications again, the notice of this action will appear in the local papers. This notice will present the rules for applying and the order in which applications will be processed.

A one-bedroom apartment can house no more than two people. An efficiency apartment can house no more than one person.

After applicants sign their HUD Lease, they are expected to occupy their apartment within 30 days of the lease signing. After 30 days, the resident must be in communication with the Manager to determine when they will move into the apartment. Not moving into the Village within the 90-day period after signing may jeopardize their residency at Bethlehem Village.

Establishing residency will mean that Bethlehem Village is a new resident’s only mailing address, and they neither own nor rent another property where they live.

Family Size/Composition

A resident requiring a unit change due to a change in family size/composition is eligible to occupy the next vacant unit when it becomes available. 

Current Resident Priority

Current residents are offered priority to accessible units for disability and/or medical reasons.

Medical Reasons

A resident requesting a unit change for medical reasons must provide the name and address of healthcare provider from whom management can request verification of the medical condition and the need for a unit transfer.

Disability

A resident with a disability must provide the name and address of a healthcare provider from whom management can request verification that the resident is disabled and needs an accessible unit to accommodate the disability.

If Management receives adequate verification (HUD form 90102) from the healthcare provider, the resident will move to the next accessible or vacant unit.

Except for the above reasons, all resident unit transfer requests will be denied.

The Violence Against Women Act (VAWA) provides legal protections to victims of domestic violence, dating violence, sexual assault, or stalking. These protections prohibit the eviction or termination of assistance from individuals being assisted under a project-based Section 8 program if the asserted grounds for such action is an instance of domestic violence, dating violence, sexual assault, or stalking. More information and procedures to apply for this protection are available from the Management Office.

Bethlehem Village is a totally smoke-free property. Smoking and the use of tobacco products is prohibited in all buildings and apartments, as well as anywhere on Village property. Tobacco products are defined as cigarettes, cigars, pipe tobacco, chewing tobacco, marijuana, and any form of electronic cigarettes and vaping devices. Residents are responsible for all guests and visitors regarding the Village Smoking Policy.

Annual Recertification Requirement

In accordance with HUD guidance, Bethlehem Village will conduct a recertification of family income and composition at least annually. Bethlehem Village will verify resident household income, assets, and expenses every year. Bethlehem Village will not accept self-certification of net family assets equal to or less than $50,000.00 (adjusted annually for inflation) for both new admissions and at annual reexamination.

Any resident household that has net family assets that exceed $100,000 and/or has present ownership interest in, a legal right to reside in, and the effective legal authority to sell the real property (based on laws of the state or locality in which the property is located) that is suitable for occupancy by the family as a residence will still be eligible for assistance.

For both admission and at reexamination, Bethlehem Village will not accept verification of a family’s income prior to the application of any deductions based on income determinations made within the previous 12-month period by any Federal or State Agency or Program.

Interim Recertification Requirement

All tenant households must notify Bethlehem Village within 30 days if there is any change. If there is any change, Bethlehem Village will conduct an interim recertification in the following areas:

  • Household composition (new member added or household member moves out)
  • Household annual adjusted income will decrease by an amount that is less than ten (9%) percent of the family’s annual adjusted income.
  • Household annual adjusted income will increase by ten (10%) percent or more in annual adjusted income. If an interim recertification reducing earned income was completed since the last annual recertification, Bethlehem Village will not complete an interim recertification adjusting earned income. An interim reexamination caused by the increase in income will not be conducted within three months of the family’s next annual reexamination effective date.

Any tenant household that has net family assets that exceed $100,000 and/or has present ownership interest in, a legal right to reside in, and the effective legal authority to sell the real property (based on laws of the state or locality in which the property is located) that is suitable for occupancy by the family as a residence will still be eligible for assistance.

De Minimis Errors in Income Determinations

Bethlehem Village will take corrective action to credit and repay a family if the family was overcharged tenant rent because of de minimis errors in calculating family income. This will be done by crediting the family’s rental account the amount that the family was overcharged retroactive to the effective date the error was made, regardless of the dollar amount associated with the error. Bethlehem Village will not require families to repay in instances resulting in a family being undercharged for rent when the owner miscalculated the family’s income.

Hardship Exemptions

Bethlehem Village will provide hardship relief for any resident household that demonstrates its eligible childcare, health and medical care expenses, or reasonable attendant care and auxiliary apparatus expenses exceed five (5%) percent of their annual income. Bethlehem Village will not extend this hardship relief past 90 days of it being granted. Hardship exemption will be granted if:

  • The resident requests a financial hardship exemption.
  • The resident participates in a review meeting.
  • The resident provides required information and signatures within ten (10) business days.
  • There is an increase to Total Tenant Payment (TTP) as described below:
    • The net cash value of assets for the entire family is $50,000 or less; and
    • The family’s total annual income is at or below the current extremely low-income limit; andThe change results in a Total Tenant Payment (TTP) that exceeds 20% of the family’s annual income.
    • The resident has not provided notice to move.
    • The resident is a resident in good standing and Bethlehem Village has not indicated intent to terminate assistance and/or terminate tenancy (eviction).

Hardship Exemptions for Health/Medical Care Expenses & Reasonable Attendant Care & Auxiliary Apparatus Expenses – Phased-In Relief: All in-place families that received a deduction for unreimbursed health and medical care and/or reasonable attendant care or auxiliary apparatus expenses based on their most recent income review prior to January 1, 2024, will begin receiving a 24-month phased-in relief at their next annual or interim reexamination, whichever occurs first on or after the date which the owner complies with HOTMA. Families who receive phased-in relief will have eligible expenses deducted as follows:

  1. 1st 12 months: in excess of 5% of income.
  2. 2nd 12 months: in excess of 7.5% of income.
  3. After 24 months: in excess of 10% .

This threshold will phase-in and remain in effect unless a family qualifies for general relief. Once a family chooses to obtain general relief, a family may no longer receive the phased-in relief. This phased-in relief policy only applies to in-place families and does not apply to new admissions whom may have been receiving phased-in relief at another property.