IHDA Home Modification Program-Frequently Asked Questions (FAQs)
This section is being added to the Application to provide more information and clarification to applicant organizations on specific issues raised at the application workshops or through separate discussions. Here were the major items brought forth:
1. Application Fee - All eligible applicants are required to submit a $250.00 application fee with each submitted application. The administrative rules for the Affordable Housing Trust Fund program require this non-refundable fee (Section 360.301), and do not provide IHDA with any waiver authority on this matter. Please note that all such fees collected for this purpose go back into the Affordable Housing Trust Fund for future funding usage.
2. Partnerships - To assist applicants in identifying and working with potential agencies or organizations to partner with which have the requisite needed experience or capacity to assist in operating such a program, a partnership resources list has been included as an addendum to the application, which is available on-line for downloading (www.ihda.org). As this is not meant to be an all-inclusive list, please contact IHDA, IDHS, or IDoA for further information on other agencies not listed here.
3. Identification/Referral of Clients - Applicant organizations are not being required to identify actual client households to be assisted as part of the Home Modification Program application, but applicants will need to request and provide such personal/confidential household information from all participants if funded to determine eligibility. An applicant organization may also need to consult with services/referral agencies for obtaining information on the local need/demand for the program for inclusion in its funding application. As is also stated in the Notice of Funding Availability, all client referrals to/with a local administering agency are to come from an IDoA- or IDHS-funded services provider agency, to help ensure that applicant households qualify for this assistance and are made aware of other resources that may be available to them. A specific referral procedure or process is not being required, but funded agencies should document the source of each referral for any applicant or assisted household. For agencies wanting to utilize an existing waiting list from another housing program, this is an acceptable source as long as the applicant household is first referred to the program through a qualifying agency, as is stated above.
4. Limiting Assistance To Eligible Homeowners - While local agencies can apply for and limit their proposed assistance to assisting only elderly persons or only persons with disabilities, the program’s stated preference is for applicants to serve both populations. The major criteria for participant eligibility is household income, regardless of tenure type, and prioritizing assisting those households who through this assistance are being prevented from being prematurely or unnecessarily institutionalized. As such, renter households cannot be automatically excluded from eligibility for assistance under a local program.
5. Household Eligibility for Future Rehabilitation Funding - IHDA can only respond to this matter as it relates to IHDA funding. Participation in this Home Modification Program does not disqualify the household for applying for funding under other IHDA-funded housing rehabilitation programs.
6. Eligibility of Certain Federally-Assisted Properties - A recommendation was made to prohibit participation in the program of all federally-assisted properties which receive(d) project-based assistance and are covered by Section 504 (of the Rehabilitation Act of 1973). It was stated that the latter coverage provides tenants residing at such properties with the right to request reasonable accessibility accommodations from the rental property owner if this does not create an undue/unreasonable financial burden on the owner. The current program guidelines allow such privately-owned properties to participate. As allowing this may actually further encourage such modifications and may in fact actually serve to reduce or eliminate the undue burden on the rental property owner, it may have a positive impact here on increasing accessible housing units. As such, IHDA will not restrict these properties from participating this year.
7. Contract for Deed - There have been questions as to whether this constitutes an eligible form of homeownership under this program, or alternatively if households occupying such homes can otherwise be eligible for assistance. It is possible that both parties to such an agreement will need to consent to the modifications. Documents used to establish eligibility here will be reviewed on a case-by-case basis.
8. Home Equity/Housing Value - First of all, a participating homeowner is not required to have any minimum level of equity in his/her home as a condition of eligibility to participate in this program. Similarly, there are no restrictions (minimum or maximum) on housing value required on participating housing properties.
9. Rehabilitation Standards/Code Compliance - The Home Modification Program is designed to provide for identified home modifications as well as repair work necessary for the health and safety of residents. All health & safety repairs being funded and provided as part of any individual home modification must be completed in compliance with HUD's Housing Quality Standards or local building code. Please note that inspections of homes and subsequent work write-ups/cost estimates may indicate that more extensive repairs /work/assistance are needed than can be provided under this program, and such households/homes may not be able to be assisted due to this program's funding limitations. Please note that Page 13 of the program application was amended, and is available on IHDA’s website.
10. Lead-Based Paint Assessment and Remediation Requirements - The applicability of federal (HUD and EPA) lead-based paint requirements is only triggered if federal assistance in excess of $5,000 is being used in combination with Trust Fund/Home Modification Program funds. There is no similar minimum threshold in State law, but there are other compliance requirements. When any rehabilitation/renovation work is being done and lead-based paint presence is suspected in the work site area, lead-safe work practices are required to be followed, which include inspection and remediation work performed by State-licensed risk assessors and contractors. Specific repairs that disturb painted surfaces in housing built prior to January 1, 1978 are examples of applicability here. In these cases, a qualified lead risk inspection is to be performed on all areas where proposed (home modifications or rehabilitation) work is to take place, to determine if and what further remediation actions are warranted as part of that work. Where lead hazards are identified, all work in the affected areas must be done by a licensed lead contractor using lead-safe work practices. Additionally, any housing where a child or pregnant woman resides who has been screened and tested positively for lead poisoning by local or state health departments must be risk-assessed to determine all sources of immediate lead-based paint hazard, and related remediation work must be performed. Lead-based paint assessment and remediation work are both eligible costs under the Home Modification Program.
11. Flood Insurance Applicability - Due to a recently issued Governor’s Executive Order (2006-05), Construction Activities in Special Flood Hazard Areas (March 7, 2006), further research of the applicability of federal construction and insurance requirements is being done in this area.
12. Historic Preservation Requirements - State standards and procedures for such properties are applicable. For those applicants approved for funding, the notification and clearance process will be subsequently further specified.
13. Repairs to Existing Home Modifications - While the major intent and focus of this funding is to provide new home modifications, a funded local agency will be allowed to make a local eligibility determination on repairing or replacing an existing home modification for the otherwise eligible applicant household if it is not functional or fully usable in its current condition.
14. Project Delivery Costs - While these are limited to 10% of individual project costs, the amount to be recorded in the required recapture agreement shall only reflect the actual home modification/rehabilitation costs expended on the home. While project delivery and eligible soft costs (e.g., recording fees, termite inspection) do come out of the maximum budget amount ($15,000.00 per home), the intent is not to pass along any of these costs to the applicant household.
15. Identity of Interest - IHDA's application (Page 10) requires applicants to identify and explain any known identity of interest situations among identified development team members so that such cases (involving family/employment/contractual relationships) are publicly stated and acknowledged.