A. Overview of Directions Paper

Purpose and Approach

On April 24, 2002, the City of Ottawa released a consultation document entitled "City of Ottawa Local Policies in Social Housing: Consultation Document: Options Paper". This paper summarized the social housing issues for which the City of Ottawa has discretion to set local policy and identified the range of options available to the City with respect to each option.

The paper was distributed to key stakeholders across the City of Ottawa, including all housing providers (cooperatives and non-profits), sector associations, service agencies and the Registry. Each stakeholder was encouraged to submit a response indicating the option it felt was most suitable for the City to adopt as its policy with respect to each option and, where possible, to explain its rationale. A total of 37 written responses were received (see Appendix for list of respondents).

At the same time, the consulting team conducted additional research on policies adopted by other service managers across Ontario, other Canadian social housing jurisdictions outside of Ontario and major social housing jurisdictions in the United States. The team also reviewed further the Social Housing Reform Act and its regulations to provide additional insight regarding the responsibilities and legal frameworks facing the City as Service Manager with respect to these issues.

The outcome of the above process is summarized in this paper, which has been entitled: "Local Policies in Social Housing--Directions Paper". The paper uses the information from the above sources to summarize directions emerging to date.

Following release of this paper, further consultation on emerging directions will take place in the form of focus groups with all key stakeholders, invitation to respond directly to the Directions Paper, additional technical research where necessary, interviews with key informants and discussions with City staff. The final outcome will be a set of recommended policies for consideration by the City of Ottawa.

Format

This Directions paper has been organized around the 23 issues identified in the Options Paper distributed on April 24, 2002. For each, the issue is outlined and the options available to the City as Service Manager are identified.

We then summarize the preferences expressed by stakeholders with respect to potential options and provide additional information from our review of other jurisdictions. It must be pointed out that many respondents expressed views only on certain issues, so there are differing numbers of responses to each issue. It is also pointed out that no specific respondents are identified, other than the Registry, which does not fit into any of the major stakeholder categories and agreed to have their responses identified.

Emerging directions are identified, based on the analysis of responses and the additional information. Remaining steps required to finalize each policy are then outlined.

B. Municipal Standards for Social Housing

1. Local Occupancy Standards

a) Background

The province established a range of occupancy standards for the purposes of determining the size and type of unit of which a household is eligible to receive rent-geared-to-income assistance. The City of Ottawa has the flexibility to establish local occupancy standards within one year of the transfer date. (Reference: SHRA section 76 and O. Reg 298/01 sections 26 to 31)

b) Service Manager Options

1. Accept the new provincial occupancy standards as set out in the regulations. These standards cover current provincial and federal standards.

2. Restrict the occupancy standards to either the current provincial or federal standard.

3. Accept the new provincial occupancy standards and add provisions which take into account special circumstances, such as allowing large families to ‘choose’ to be underhoused.

4. Set occupancy standards that consider a combination of rooms per unit and size of bedrooms (i.e. square footage)

c) Stakeholders' Preferred Options

The following provides a breakdown of the preferred options identified by type of stakeholders.

Stakeholder	Option 1	Option 2	Option 3	Option 4
Co-operatives	3	-	1	1
Non-Profits	5	2	4	-
Sector Organization	1	-	-	1
Service Agency	1	-	4	1
The Registry	-	-	1	-

d) Additional Information from Other Jurisdictions

A survey taken by ONPHA reports the following:

· 22 Service Managers have adopted the new provincial standard for the time being, leaving the option open for future review.

· 22 Service Managers reported that they are currently consulting stakeholders before making a decision.

· 3 Service Managers reported that they have set up local standards differing from the provincial standard.

In the City of Toronto, the provincial standard has been accepted, with the following provisions:

· children of the opposite sex are allocated separate bedrooms

· two children of the same sex are allocated one bedroom until the older child turns 16. If the age difference between the children is 5 years or more, the older child will be eligible for a separate bedroom at age 12; if the bedroom to be shared does not meet minimum municipal property standard code (minimum of 4 sq. metres), then a separate bedroom is allocated

· persons other than spouses or same sex partners who have reached age 16 are allocated one bedroom

· Children of the opposite sex are allowed to share one bedroom, provided their parents/guardians desire such an arrangement. Single parents are allowed to share a bedroom with children of the same sex if the applicants so desire.

An additional bedroom may be allocated for any of the following reasons:

· medical condition

· if a member of the household is pregnant and the provision of bedroom space for the child would entitle the household to an additional bedroom

· a member of the household has joint custody of a child

· a member of the household has visiting rights with respect to a child

· if a child is away at school

Other Canadian jurisdictions outside of Ontario have established occupancy standards. Manitoba and Nova Scotia follow the CMHC national occupancy standard. In Quebec, studio apartments must be allocated to single persons while spouses/partners must share one bedroom (unless there is a medical exception). Others of the same sex can share a bedroom, and others of opposite sex can share a bedroom if they are less than 7 years old. An additional bedroom shall be allocated to a handicapped person if their handicap prevents them from sharing a bedroom.

In Alberta, it is not permitted for more than 2 persons to share a bedroom. Spouses/partners must share one bedroom (unless there is a medical exception), and individuals under 5 years of age must share a bedroom, regardless of sex. In British Columbia, there must be no more than 2 persons per bedroom and no fewer than 1 person per bedroom. Parents do not share a bedroom with children and dependent persons age 18 or older do not share a bedroom. Individuals age 5 or over of the opposite sex do not share a bedroom. No more than one person is permitted in a studio unit.

The major US housing jurisdictions have established similar occupancy standards. HUD (the federal government department responsible for housing) actually permits PHAs (Public Housing Authorities) to establish occupancy standards, but encourages them to follow HUD guidelines, which include generally 2 persons per bedroom (or in accordance with local occupancy bylaws). The New York City Housing Authority uses standards based on family size and composition--single persons can occupy bachelor or 1 bedroom units, two person households can occupy 1 or 2 bedroom units depending on household composition, three person households occupy two bedroom units, four person households occupy 2-3 bedroom units, etc. A separate bedroom may be provided due to a permanent health condition.

The Boston Housing Authority and Chicago Housing Authority have similar occupancy standards. In addition, in Boston, children of the opposite sex cannot share a bedroom. Also, children of the same sex 10 years apart in age where the older child is at least 14 cannot share a bedroom. Individuals of the same sex but a different generation cannot share a bedroom. In Chicago, children of the same sex within 7 years must share a bedroom. Children temporarily away from home (eg. at school) are considered as part of the household.

e) Emerging Directions

The responses from stakeholders, while showing some variation, essentially are supporting the same theme--that the provincial standards set out in the regulations are generally satisfactory, but that some special circumstances need to be considered. Flexibility is a key consideration.

In particular, special attention needs to be paid to permitting applicants to choose to be underhoused if they so desire. Similarly, exceptions need to be made in circumstances of urgent need, such as an abused spouse in urgent need of accommodation. There also needs to be flexibility to consider the size of bedrooms as well as the number of bedrooms, given the small unit sizes in some projects. Standards need to respect local City bylaws for minimum square footage per occupant.

Various jurisdictions have varying standards regarding the age at which a child is entitled to his/her own bedroom. Further discussion is required on this point to arrive at consensus on specific standards in this regard.

f) Next Steps to Finalize Policy

Conduct further consultation during the focus groups with key stakeholders to arrive at specific rules for:

· the age at which a child is entitled to his/her own bedroom;

· determining exceptional circumstances;

· standards according to bedroom size;

· minimum square footage per occupant.

Additional research will be undertaken to identify local municipal occupancy by-laws, current practices amongst housing providers and the impact of suggested options on the waiting list for social housing.

2. Local Priority Rules

a) Background

The province mandated one special priority category, victims of abuse, in the SHRA. The City of Ottawa may establish local priority rules for rent-geared-to-income assistance in addition to the one special priority category mandated by the province. The local priority rule(s) may take effect on a date specified by the City as service manager. (Reference: SHRA section 77 (4)-(7) and O. Reg 298/01 sections 41 and 42)

b) Service Manager Options

1. Set no additional local priority rules

2. Set local priority rules for groups disadvantaged by the chronological waiting list. Some examples of groups that might be given priority access include:

· Newcomers to Canada

· Youth (16 and 17 year olds)

· Homeless people

3. Set local priority rules to address the need to relieve the hardship or economic disadvantage of persons or groups, including:

· Families separated due to lack of adequate shelter

· Terminally ill people

· People ready to leave hospital who cannot return to their former home

· People living in housing condemned by the municipality

· People whose home has been destroyed

· Families with children in custody, who need adequate housing before their children can be returned

c) Stakeholders' Preferred Options

The following provides a breakdown of the preferred options identified by type of stakeholders.

Stakeholder	Option 1	Option 2	Option 3
Co-operatives	8	1	-
Non-Profits	6	1	3
Sector Organization	2	-	-
Service Agency	3	3	4
The Registry *	-	-	-

* The Registry Board of Directors could not reach consensus.

d) Additional Information from Other Jurisdictions

In a survey of Service Managers, ONPHA found that:

· 50% have decided not to create local priority access categories

· 15% are still involved in local consultation

· 35% have adopted a range of local priorities

Some that are not creating local priority access categories are grandparenting those who were previously granted "priority/urgent" status in that category with their original date of application.

The Region of Waterloo has adopted two priority categories:

· homeless--defined as physically homeless or if the family has been separated due to a lack of housing;

· severe medical urgency.

At least 1 in 10 of new applicants should come from these categories.

The City of Toronto has adopted the following priorities:

· First priority--victims of violence as per the Act

· Second priority--terminally ill member of household (optional for all housing providers)

· Third priority--overhoused applicants required to apply for transfer

· Fourth priority--1 in 10 RGI vacancies will be filled by households who are disadvantaged, including:

- homeless

- separated families

- newcomers to Canada

- youths age 16 to 17 at time of application

Also, all market rent households applying for RGI assistance with their current housing provider will receive a ranking date that is the date of original application or date of signing of initial lease. All market rent households seeking RGI unit in another project will be considered new application.

The City of Toronto is also pursuing changes to Bill 128 to include local access priorities for groups with special ethnic and community mandates. They are still studying the rationale for newcomers to Canada being included as a priority and for the 1 in 10 provision under the household disadvantaged designated list to be changed to 1 in 5.

York Region and Peel Region have both decided to have no priority groups other than victims of violence.

In terms of other Canadian jurisdictions, the Provincial government regulates priority access in Manitoba, Quebec, Nova Scotia and British Columbia. In each of these provinces (except Alberta), the province specifies specific priority groups. Each province except Alberta gives priority to victims of family violence. In Quebec, applicants can also be given priority due to psychological or health factors.

Similarly, major jurisdictions in the US also have established priority categories. HUD encourages preference be given to households with less than 30% of the median income for the area. In New York City, priority is given to two groups--the "Working Family" Category, where household income is well below the median for the area and the "Need Based" Category, in the following order:

· city-referred homeless

· victims of domestic violence

· intimidated witnesses

· non-city referred homeless

· families displaced by disaster or no fault eviction

· working families in substandard conditions

New York tries to rent 50% of its vacancies each year to applicants from Working Family Category.

In Boston, the first priority includes:

· victims of natural disasters

· victims of domestic violence

· victims of hate crimes

· individuals in witness protection

· no fault evictions

The second priority is homeless persons.

In Chicago, priority is established according to "Tiers" based on incomes below the median for the area, with top priority to households with incomes at 0-30% of median. Within these tiers, priority is given in the following order to:

· victims of domestic violence

· upwardly mobile families (where an adult is working at least 20 hours per week, attending an educational institution full-time or participating in job training)

· applicants whose children are at risk of being placed outside the household

· elderly or near elderly

· disabled

Within any given year not less than 50% of the household admitted will have incomes between 0-30% of the area median income.

e) Emerging Directions

While there is some support for a wide range of priorities, by far the majority of local stakeholders (20 of 32 responding to this issue) feel that it is fundamentally unfair to place the needs of one disadvantaged group ahead of the needs of another (other than victims of domestic violence as required by the Act). There is also considerable support for in-situ residents paying market rent who experience a substantial drop in income and require an RGI unit. A wide number of providers, especially cooperatives, believe strongly that it is unfair to place these households at the bottom of the waiting list and that they should be accorded priority status according to their original date of application. The category of "homeless" is also of strong priority to many, depending on its definition.

It is interesting to note that, while almost all providers (16 of 21) prefer Option One, only 3 of 10 service agencies prefer Option One. Service agencies generally support various disadvantaged groups and appear to believe that it is suitable to rank the needs of particular groups.

While most other Service Managers surveyed appear to favour few or no other priorities beyond the legislation, there is fairly wide concern for individuals with severe medical conditions. Also, the issue of overhoused residents requiring transfer to smaller units, while not noted in many submissions, has been identified as a priority in areas such as the City of Toronto and appears to require special attention in the City of Ottawa in view of the requirements of the Act and its regulations. Outside jurisdictions do appear to identify extensive ranges of priority categories, including some American examples targeting lower income groups (similar to the old definition of "core need") and some interesting approaches to giving priority to households specifically identified as upwardly mobile in order to encourage self-improvement.

f) Next Steps to Finalize Policy

Because of its importance, the area of priority access should be the subject of further specific consultation. However, it would appear that the direction being favoured by most stakeholders is to have few, if any, priority categories beyond victims of domestic violence and to permit existing market rent tenants requiring RGI assistance to be placed on the waiting list according to their original date of application. The category of "homeless" also appears to be a strong priority to many, depending on its definition, and should perhaps be considered further. Discussion needs to also be focused on the approach to dealing with residents who are or become overhoused.

It is also important to note the divergence of viewpoint between providers and service agencies. While the majority of providers (both coops and non-profits) and their sector associations favour no additional priority categories, most service agencies do identify disadvantaged groups that they believe should receive priority. This divergence of viewpoints and the reasons behind such differences should be discussed during the further consultations taking place.

Further consultation on this issue will include focus group sessions, consultation with HSAG and City staff, as well as an analysis of the impact of various options on the current waiting list. In addition, any legal constraints imposed by the Social Housing Reform Act with respect to treatment of market rent tenants applying for RGI units will be analyzed in more detail.

C LOCAL RGI ELIGIBILITY RULES

3. Maximum Gross Household Income (Income Limits)

a) Background

The service manager may consider establishing income limits in order to meet provincial standards on the number of RGI units in its area. Service managers are only able to count households whose incomes fall below the Household Income Limit (HIL) for their area. Household Income Limits in the City of Ottawa as per O. Reg 368/01are as follows:

Bachelor Unit: $19,500 or rent of $488/month

One Bedroom Unit: $24,500 or rent of $613/month

Two Bedroom Unit: $30,000 or rent of $750/month

Three Bedroom Unit: $36,500 or rent of $913/month

Four Bedroom Unit: $40,000 or rent of $1,000/month

The City of Ottawa may establish a local eligibility rule stating that a household is not eligible for rent-geared-to-income assistance in a unit in the service area unless the gross household income of the household is less than or equal to the maximum gross household income amount applicable to the unit, as specified in the local eligibility rule. The local rule may not set a income limit that is less than the HIL. This local rule may take effect on a date specified by the City as service manager and may be replaced from time to time. (Reference: O. Reg 298/01section 8 (1) & (2) and subsections 8 (5)(a), (6), (7), (9) and O. Reg 368/01 Table 2)

b) Service Manager Options

1. Not set an income limit

2. Set income limits at the Household Income Limit established in O. Reg 368/01

3. Set income limits above the Household Income limit specified in O. Reg 368/01

4. Set different income limits for units of different sizes and for units in different parts of the service area

c) Stakeholders' Preferred Options

The following provides a breakdown of the preferred options identified by type of stakeholders.

Stakeholder	Option 1	Option 2	Option 3	Option 4
Co-operatives	5	2	-	2
Non-Profits	6	1	-	2
Sector Organization	2	-	-	-
Service Agency	-	4	1	1
The Registry	1	-	-	-

d) Additional Information from Other Jurisdictions

In a survey conducted by ONPHA:

· 63% of Service Managers are still studying the issue

· 24% are not setting an income limit

· 13% are using provincial HILs

Neither York Region nor Waterloo Region are establishing income limits, although Waterloo intends to re-examine the issue within 6 months.

Income limits are regulated in Manitoba, Quebec, Nova Scotia, Alberta and British Columbia. Manitoba utilizes CMHCs Household Threshold Limits. In Quebec, seniors must have a maximum income below the amount of the guaranteed income supplement paid under the Old Age Security Act, while singles and families must have incomes at or below the maximum amount applicable under the Canada-Quebec Global agreement on social housing. In Nova Scotia, households must be in "core housing need", using CMHC's Core Need Income Threshold. In Alberta, households must be below the core need threshold the Province establishes for each municipality, although there is no income limit on seniors applying for supportive housing. In BC, for units built after 1986, household income must be below CMHCs Core Need Income Threshold.

In major US jurisdictions, income limits are also set. HUD sets income limits for admission to public housing at 80% of the median income for the area. All other jurisdictions observe this limit.

e) Emerging Directions

The majority of respondents favour no income limit, as the RGI rent calculation effectively sets an income limit at market rent. As noted by the Registry, incomes of many applicants fluctuate constantly and setting limits would penalize many who have been on the waiting list for a long time. While there is some support for setting some type of limits, and indeed this is done in many other jurisdictions, it appears that the shortage of units in Ottawa is so severe at present that setting income limits would likely exclude large numbers of applicants with few other housing options. While many other Service Managers are still studying the issue, the majority who have decided on a policy are favouring no income limit.

Here again, it is interesting to note the divergence of opinion between providers and service agencies. The majority of responding providers, as well as both sector associations and the Registry preferred no limits, while all service agencies preferred some form of limit. Clearly, agencies believe strongly that eligibility for RGI housing should be limited to those at the neediest end of the income scale, while most providers and the Registry believe income limits would exclude many households in need.

f) Next Steps to Finalize Policy

Consult further on this issue during the focus groups with key stakeholders to resolve the divergence of views. Conduct further research in association with housing providers on the number of RGI households that currently exceed the household income limits set by the province.

4. Maximum Aggregate Assets Value of Household (Asset Limits)

a) Background

The legislation allows service managers to set an asset limit for the purposes of determining RGI eligibility. The City of Ottawa may establish a local eligibility rule stating that a household is not eligible for rent-geared-to-income assistance in a unit in the service area unless the aggregate household assets of the household is less than or equal to the maximum aggregate household assets amount applicable to the unit, as specified in the local eligibility rule. The asset limit may not be lower than $20,000. This local rule may take effect on a date specified by the City as service manager and may be replaced from time to time. (Reference: O. Reg 298/01 section 8 (3) & (4) and subsections 8. (5) (b), (8), (11), (12))

b) Service Manager Options

1. Not set an asset limit

2. Set an asset limit at $20,000

3. Set an asset limit higher than $20,000

4. Set different asset limits for units of different sizes and for units in different parts of the service area

c) Stakeholders" Preferred Options

The following provides a breakdown of the preferred options identified by type of stakeholders.

Stakeholder	Option 1	Option 2	Option 3	Option 4
Co-operatives	5	1	3	-
Non-Profits	5	1	1	2
Sector Organization	2	-	-	-
Service Agency	-	3	1	1
The Registry	1	-	-	-

d) Additional Information from Other Jurisdictions

In its survey of Service Managers, ONPHA found that:

· 65% are still studying the issue and have not yet made a decision

· 28% are not setting asset limits

· 7% have chosen to set a specific limit.

The Region of Waterloo has not set an asset limit, but is revisiting the issue in 6 months. They intend to analyze the waiting list to determine what impact an asset limit would have on excluding some applicants.

The Region of York is interested in setting an asset limit. They are studying the definition of an asset and the differing impact of asset limits on seniors vs. non-seniors. They also intend to analyze the waiting list to determine what kind of assets are held by those on the waiting list.

Manitoba, Quebec, Nova Scotia and BC have no asset limits, although assets are taken into account in setting RGI rents. In Alberta, non-seniors have an asset limit of $7,000, while seniors have no asset limit, although they lose points in the priority system for every $1,000 in assets over $2,500.

In major US jurisdictions researched, there are no asset limits. Revenue from assets are taken into account in rent calculations in all areas.

e) Emerging Directions

The most widely supported option is Option One--no asset limits. It is pointed out that the RGI rent calculation takes assets into account in setting rents, so the system is self-regulating. The Registry points out that few applicants have assets of any significance, so setting a limit is unnecessary in reality and would cause an unnecessary administrative burden and cost. The issue of RRSPs being considered assets while pensions are not is a major concern, especially for seniors. Most other Service Managers who have decided their policy and most outside jurisdictions have not set asset limits.

Here again, it is interesting to note that, while the majority of providers, the sector associations and The Registry favour no limits, all responding service agencies favour some form of limit. Again, it appears service agencies support the position that eligibility for RGI housing should be limited to the neediest, while providers generally support the position that limits would exclude many households in need.

f) Next Steps to Finalize Policy

Consult further on this issue during the focus groups with key stakeholders to resolve the divergence of views and conduct further research as appropriate.

5. Exclusion of Specified Payments for Income Calculation

The regulations include a list of excluded income and assets. See O. Reg subsection 8(12). Service managers may add to this list. The City of Ottawa may establish a local eligibility rule requiring that specified payments be excluded for the purpose of determining the gross household income of a household. This local rule may take effect on a date specified by the City as service manager and may be replaced from time to time. (Reference: O. Reg 298/01 section 8 (10), (11), (12), (13))

b) Service Manager Options

1. Accept the list of excluded payments identified in the legislation

2. Add to the list of excluded payments

c) Stakeholders' Preferred Options

The following provides a breakdown of the preferred options identified by type of stakeholders.

Stakeholder	Option 1	Option 2
Co-operatives	8	1
Non-Profits	9	-
Sector Organization	1	-
Service Agency	3	2
The Registry	-	-

d) Additional Information from Other Jurisdictions

ONPHA did not conduct a survey of Service Managers on this issue. The Region of York and the Region of Waterloo are accepting the provincial list of exemptions. Other Canadian provinces and major jurisdictions in the US surveyed use a similar list, with some local variations. In Nova Scotia, a one-time withdrawal from an RRSP is a permitted exclusion. In Alberta, assets in pension funds, RRSPs or RRIFs are permitted exclusions.

e) Emerging Directions

There is widespread support for accepting the list as identified in the legislation, although some interesting points have been raised about specific exemptions for withdrawals of RRSPs and RRIFs, for volunteer work and for housing assistance in times of crisis. The proposed policy direction should be to accept the list in the legislation, subject to further consultation on the items raised.

f) Next Steps to Finalize Policy

Consult further during the focus groups with stakeholders on acceptance of the list of exclusions identified in the legislation, with the possible addition of withdrawals of RRSPs and RRIFs, exemptions for living expenses received while performing volunteer work and exemptions for housing assistance during times of crisis.

6. Divestment of Residential Property

a) Background

The legislation requires that a household receiving RGI assistance must divest itself of its interest in residential property suitable for year-round occupancy within 180 days after the first day of the month that the household receives RGI assistance. The City of Ottawa may extend the time for effecting the divestment of residential property and giving the notice for such period of time as the City considers appropriate, if the City is satisfied that there are reasonable grounds to do so. This local rule may take effect on a date specified by the City as service manager and may be replaced from time to time. (Legislative Reference: O. Reg 298/01 subsection 9 (3))

b) Service Manager Options

1. Accept the provisions set out in O. Reg 298/01 subsection 9 (1) & (2) requiring divestment of residential property within 180 days

2. Extend the time period for divestment of residential property to take into account local market conditions

3. Accept the provisions set out in O. Reg 298/01; however add a provision for the service manager or housing provider to consider extending the time period on a case-by-case basis

c) Stakeholders' Preferred Options

The following provides a breakdown of the preferred options identified by type of stakeholders.

Stakeholder	Option 1	Option 2	Option 3
Co-operatives	1	2	6
Non-Profits	2	1	5
Sector Organization	-	-	1
Service Agency	-	2	5
The Registry	-	-	1

d) Additional Information from Other Jurisdictions

ONPHA did not conduct a survey of Service Managers on this issue. York Region and Waterloo Region have not established local policies on this issue as of yet. Manitoba, Quebec, Alberta and BC have no regulations regarding timeframe for sale of residential property. In Quebec, this is essentially a non-issue, as most applicants do not own property and those who did would have a low eligibility evaluation. In Alberta, applicants would receive a low priority if they continued to own property. BC Housing applies an imputed rate of return on property and includes that as income. In Nova Scotia, there is a 6 month time period for sale of residential property, but extensions can be granted on a case-by-case basis at the discretion of the Local Housing Authority due to market conditions. None of the major US jurisdictions surveyed require sale of residential property; but any income from the property is included in the calculation of RGI rent.

e) Emerging Directions

There is widespread support for accepting the 180 day time period set out in the regulations with an added provision to permit extensions on a case-by-case basis for legitimate reasons, particularly when market conditions are weak. Most respondents favoured permitting the individual housing provider to make such decisions.

f) Next Steps to Finalize Policy

Consult further during the focus groups on the emerging policy direction and conduct additional research, as required.

7. Maximum Absence From A Unit

a) Background

The legislation allows service managers to set a rule on the maximum length of time that RGI households may be absent from their unit and still be eligible for RGI assistance. Absence due to a medical reason is an exception to this rule. The City of Ottawa may establish a local rule stating that, a household receiving RGI assistance ceases to be eligible for such assistance if all of the members of the household have been absent from the unit for at least a maximum absence period specified in the rule. The legislation does not permit the City to set a maximum absence period that is less than 60 days. This local rule may take effect on a date specified by the City as service manager and may be replaced from time to time. (Legislative Reference: O. Reg 298/01 section 13 (1) (a) and subsections 13 (2), (3) & (4))

b) Service Manager Options

1. Not set a rule

2. Set a policy permitting absences from units up to a fixed number of days, but not less than 60 days

3. Set a policy which allows providers to set conditions for approving absences from units of more than 60 days

c) Stakeholders' Preferred Options

The following provides a breakdown of the preferred options identified by type of stakeholders.

Stakeholder	Option 1	Option 2	Option 3
Co-operatives	2	-	7
Non-Profits	-	2	8
Sector Organization	-	-	2
Service Agency	1	-	8
The Registry	-	-	-

d) Additional Information from Other Jurisdictions

In its survey of Service Managers, ONPHA found the following:

· 68% were still studying the issue

· 26% permit 60 days

· 6% permit 90 days

Several Service Managers permit the housing provider discretion for exceptional circumstances.

York Region is considering 90 days. Waterloo Region permits 60 days with the housing provider having discretion for exceptional circumstances.

None of the other provinces has established provincial rules on the subject. In Nova Scotia, Housing Authorities can use their own discretion. Halifax deals with the issue on a case-by-case basis.

A similar process is followed in Alberta. In Edmonton, households are allowed an absence of up to 4 months for legitimate reasons, which usually involve personal illness, care giving responsibilities or having to settle affairs in other jurisdictions. When absent, they must leave someone else responsible for the unit and work out a formula for paying the rent. In Calgary, if the absence exceeds 60 days, the Housing Co. conducts a review. Each case is dealt with on a case-by-case basis.

In major US jurisdictions, local public housing authorities establish rules on maximum length of absence. Typically, residents must inform management about absences beyond 2 weeks. Persons who are institutionalized may retain the right to return to their unit as long as they pay rent and their institutionalization is not permanent. In Chicago, households who are absent for more than 30 days and have not notified management and have not paid rent are removed.

e) Emerging Directions

Most respondents favour a maximum period of absence, although there is split opinion about whether 60 days or 90 days is preferable. Virtually all respondents favour allowing housing providers discretion for exceptions to the maximum, based on legitimate reasons. There is some support for having the Service Manager define "legitimate medical reasons", although many felt the housing provider can decide for themselves what constitutes legitimate cause (medical or otherwise). Outside jurisdictions essentially follow the same principle--limiting absences and permitting discretion on a case-by-case basis.

f) Next Steps to Finalize Policy

Consult further during the focus groups with key stakeholders on the emerging policy direction and determine the preference between 60 days and 90 days. Discuss definition of medical reasons and determine whether a Service Manager definition should be provided as a guideline.

8. RGI Ineligibility Period

a) Background

The legislation states that there is an automatic two year period of ineligibility for future RGI assistance if a member of a household has been convicted in the Courts of fraud or found by the Rental Tribunal to have misrepresented income in relation to the receipt of RGI assistance. The City of Ottawa may establish a local eligibility rule that extends the two year ineligibility period for RGI assistance if a member of a household has been convicted of fraud or misrepresentation of income in relation to receipt of RGI assistance. This local rule may take effect on a date specified by the City as service manager and may be replaced from time to time. (Legislative Reference: O. Reg 298/01 sections 16 and 17)

b) Service Manager Options

1. Not set a rule, accept the automatic two year period of ineligibility legislated by the province.

2. Set a policy that extends the ineligibility period beyond two years

c) Stakeholders' Preferred Options

The following provides a breakdown of the preferred options identified by type of stakeholders.

Stakeholder	Option 1	Option 2
Co-operatives	6	4
Non-Profits	7	2
Sector Organization	2	-
Service Agency	9	-
The Registry	1	-

d) Additional Information from Other Jurisdictions

ONPHA did not survey Service Managers on this issue. York Region is adopting the 2 year rule. In other provinces, there is no specific provincial legislation on the issue and discretion is left to local housing authorities to be dealt with on a case-by-case basis. In BC, if a tenant has misrepresented income they are required to repay the debt before they can re-apply. In major US jurisdictions surveyed, cases are dealt with on a case-by-case basis. In Boston, persons making fraudulent applications are deemed ineligible for subsidy for a period determined on a case-by-case basis depending on the circumstances. In Chicago, there is generally a one year period from the time the misrepresentation is discovered, depending on the circumstances.

e) Emerging Directions

The vast majority favour the 2 year period to re-apply, although some suggest a more stringent penalty. Given the length of the waiting list, this is a very tough penalty in the City of Ottawa and should be a strong deterrent to fraud. Some favour some discretion with the housing provider for extenuating circumstances.

f) Next Steps to Finalize Policy

Consult further during the focus group stage to the emerging policy direction and conduct additional research, as required.

9. Rent Increases of Less than $10

a) Background

The legislation sets out rules for the review and calculation of RGI rent payable. The City of Ottawa may establish a local rule that should the RGI rent payable by a household be increased by less than $10, the service manager may decide to implement the increase or not implement the increase. This local rule may take effect on a date specified by the City as service manager and may be replaced from time to time. (Legislative Reference: O. Reg 298/01 subsection 52 (9) (a))

b) Service Manager Options

1. Set a policy that requires RGI rent increases, each time the amount of RGI payable increases

2. Set a policy whereby an increase in RGI rent payable of less than $10 will not be implemented

3. Set a policy whereby an increase in RGI rent payable of less than $10 will not be implemented, except at the annual review

c) Stakeholders' Preferred Options

The following provides a breakdown of the preferred options identified by type of stakeholders.

Stakeholder	Option 1	Option 2	Option 3
Co-operatives	1	-	6
Non-Profits	-	-	11
Sector Organization	1	-	1
Service Agency	-	4	4
The Registry	-	-

d) Additional Information from Other Jurisdictions

ONPHA did not survey Service Managers on this issue. York Region will implement rent increases of less than $10, but only at the annual review. Waterloo Region is still considering its policy on this issue. None of the other jurisdictions we consulted had a policy on this issue.

e) Emerging Directions

There is widespread support for only implementing RGI rent increases of less than $10 at the time of the annual review. Concern has been expressed, particularly among larger providers, that the time and cost of more frequent changes would likely outweigh any revenue gains. However, given that the annual review takes place, there would be no additional time or cost in implementing such increases at that time.

f) Next Steps to Finalize Policy

Consult further during the focus groups on the emerging policy direction and conduct additional research through key informant interviews.

10. Fraud Control

a) Background

The legislation allows service managers to establish a fraud control unit or designate individuals as ‘eligibility review officers’ for RGI assistance, just as it is currently done for Ontario Works. The City of Ottawa may set up a fraud unit or assign this duty to a local fraud unit. This local decision may be made at any time after transfer. (Legislative Reference SHRA, subsection 158 (2))

b) Service Manager Options

1. Choose not to set up a fraud control unit

2. Establish a unit as an internal department

3. Delegate the function to a third party

c) Stakeholders' Preferred Options

The following provides a breakdown of the preferred options identified by type of stakeholders.

Stakeholder	Option 1	Option 2	Option 3
Co-operatives	7	2	2
Non-Profits	3	3	3
Sector Organization	1	-	-
Service Agency	7	-	1
The Registry	1	-	1

d) Additional Information from Other Jurisdictions

ONPHA did not survey Service Managers on this issue. The Region of York is currently examining this issue. The primary concern for Service Managers is the level of resources required for the Service Manager to carry out this function. The role of the family support worker in fraud control is being examined, as the FSW is used to dealing with the police and courts. They believe deterrence is important. None of the other jurisdictions we consulted had specific fraud control units.

e) Emerging Directions

The majority of stakeholders prefer to leave the responsibility for fraud control with housing providers, as they are closest to the situation and best able to detect and deal with fraud. There is considerable concern that the costs of establishing and operating a fraud control unit would outweigh any gains in revenues. Large providers have not found evidence of widespread fraud.

At the same time, however, there is support for closer links between providers and municipal social services to be able to use social service resources as a back-up where appropriate. There is also support for the role of the Service Manager in conducting random audits to check for fraud among residents or providers themselves.

f) Next Steps to Finalize Policy

Discuss advantages and disadvantages of emerging policy direction during the focus groups and interviews with key informants. Meet with social service representatives to discuss establishing closer linkages and support system for housing providers.

11. Rent Reimbursement

a) Background

The legislation states that a tenant who has underpaid his/her rent due to a calculation error may be asked to reimburse the over-paid subsidy to the service manager, but the monthly surcharge can be no more than 10% of the correct rent. The City of Ottawa needs to decide whether or not to pursue rent reimbursement and identify whether the service manager or housing provider would be responsible for pursuing rent reimbursement. This local decision may be made at any time after transfer. This local decision needs to be co-ordinated with local decisions made on financial testing and co-ordinated access. (Legislative Reference: O. Reg 298/01 section 54)

b) Service Manager Options

1. Choose not to pursue rent reimbursement

2. Pursue rent reimbursement and assume the responsibility for pursuing reimbursement

3. Pursue rent reimbursement and delegate the responsibility for pursuing reimbursement to housing providers

c) Stakeholders' Preferred Options

The following provides a breakdown of the preferred options identified by type of stakeholders.

Stakeholder	Option 1	Option 2	Option 3
Co-operatives	3	-	6
Non-Profits	5	-	4
Sector Organization	2	-	-
Service Agency	8	-	-
The Registry	-	-	-

d) Additional Information from Other Jurisdictions

ONPHA did not survey Service Managers on this issue. None of the other jurisdictions we consulted had a policy on this issue.

e) Emerging Directions

The majority of stakeholders support the position that if a provider makes an error, the tenant should not have to reimburse the amount. It is felt that this will make providers more careful with their calculations and that the cost of pursuing reimbursement could outweigh the gains. It is also pointed out that under the Tenant Protection Act, pursuing such reimbursement is problematic.

It is interesting to note that, while all service agencies and both sector associations favour the above policy, the majority of providers (10 of 18) believe that if an error is discovered, the error should be corrected and the required amount reimbursed, especially if the City can help cover the cost of pursuing reimbursement. It is felt by these stakeholders that the individual provider should pursue reimbursement. Clearly, these providers are concerned about the impact on their financial position and believe it is fair to seek reimbursement in order to minimize financial impacts.

Given these concerns, we believe that, while not pursuing reimbursement is probably the most suitable policy direction for the reasons noted above, there should be further discussion on approaches for reducing the potential for errors. Further, it may be appropriate for providers to review cases on an individual basis, depending on the magnitude of the error. If the error is small, there is little to be gained by pursuing reimbursement, but in the case of a large error, it may be important to pursue reimbursement.

f) Next Steps to Finalize Policy

Seek further input on the proposed policy during focus group discussions. Also, explore approaches for reducing potential errors (e.g. more provider training on rent calculations) and discuss allowing housing provider to pursue reimbursement in the event of a large error.

12. Ten (10) Day Rule for Reporting Changes in Information

a) Background

The legislation requires that a RGI household must inform the service manager (or delegate) of any changes in their information within 10 days of the change. A recent amendment to the legislation allows service managers to extend the 10 day period for households to inform the service manager (or delegate) of changes in their information if the household has not started to receive RGI assistance (i.e. they are an applicant) and if they are household receiving RGI assistance. (Legislative Reference: O. Reg 298/01 subsection 5(5), 10 (1) (a) and amendments)

b) Service Manager Options

1. Maintain the 10 day requirement to inform the service manager (or delegate) of changes in household information for applicants and households receiving RGI assistance

2. Extend the 10 day requirement to inform the service manager (or delegate) of changes in household information for applicants and households receiving RGI assistance

c) Stakeholders' Preferred Options

The following provides a breakdown of the preferred options identified by type of stakeholders.

Stakeholder	Option 1	Option 2
Co-operatives	1	8
Non-Profits	3	8
Sector Organization	-	1
Service Agency	1	7
The Registry	-	1

d) Additional Information from Other Jurisdictions

ONPHA did not survey Service Managers on this issue. York Region and Waterloo Region are consulting on this issue. Waterloo is taking the fundamental position that it will not be too strict with this issue and may extend the time frame. None of the other jurisdictions we consulted reported policies in this area.

e) Emerging Directions

There is strong support among stakeholders for extending the reporting period for changes. There is virtual unanimous support for excluding applicants on the waiting list from the 10 day rule, as the length of their wait makes the reporting of changes to their income irrelevant until the time of housing. It is important that they keep the Registry informed of changes in contact information so they can be reached when necessary. The current Registry practice of annual updates appears quite reasonable and suitable.

In terms of reporting of changes in circumstances by existing residents, it appears a strong majority favour extending the reporting period to 30 days, as this is the most suitable time to obtain documentation about changes and provides a reasonable amount of time for residents to report changes and for providers to deal with them.

f) Next Steps to Finalize Policy

Consult further during the focus groups with stakeholders on the emerging direction. Review legislation and recent amendment to ensure the more lenient approach is permissable.

13. Determining RGI Eligibility

a) Background

The legislation assigns the responsibility of financial testing, including determining RGI eligibility, to the service manager. The service manager may delegate this responsibility to a third party. The City of Ottawa must determine who will be responsible for assessing RGI eligibility at various times of the process (e.g. at application, occupancy, annual). This local decision needs to be co-ordinated with local decisions made on other aspects of financial testing and co-ordinated access. (Legislative Reference: SHRA section 66)

b) Service Manager Options

1. Choose to manage the role of determining RGI eligibility

2. Delegate the role of determining RGI eligibility to The Registry

3. Delegate the role of determining RGI eligibility to housing providers

4. Delegate the role of determining RGI eligibility to another community agency

5. Delegate the role of determining RGI eligibility to different parties (e.g. housing providers, The Registry), depending on the stage of the review process (e.g. at application stage, after the applicant is housed)

c) Stakeholders' Preferred Options

The following provides a breakdown of the preferred options identified by type of stakeholders.

Stakeholder	Option 1	Option 2	Option 3	Option 4	Option 5
Co-operatives	-	-	6	-	3
Non-Profits	-	1	3	-	6
Sector Organization	-	-	-	-	1
Service Agency	-	-	2	-	6
The Registry	-	-	-	-	1

d) Additional Information from Other Jurisdictions

In its survey of Service Managers, ONPHA found the following:

· 87% have delegated or will be delegating financial testing (including determining RGI eligibility) to providers

· 13% are centralizing financial testing functions.

In Waterloo, five providers at key geographical locations have been designated as access centres and will assess basic RGI eligibility at time of application, much like the Ottawa Registry does at present. Housing providers will determine final RGI eligibility when unit is available. The Region is employing an "Access and Income Testing Coordinator" at head office who will help train access centres and all providers in determining RGI eligibility and conducting financial testing and will act as a resource for providers. See Issue #14 for information on income verification and rent calculation process in other jurisdictions.

e) Emerging Directions

There is virtual unanimity on this issue. Those respondents who selected Option #3 were actually addressing only the determination of RGI eligibility upon the offer of a unit, which is consistent with respondents who selected Option #5. Attempting to involve the Service Manager would result in a major administrative burden, although there does need to be a system of monitoring performance of providers to ensure accuracy.

The emerging policy direction, therefore, is to maintain the current system of simple self-disclosure at the Registry upon initial application and determination of RGI eligibility by housing providers at the time a unit is offered.

f) Next Steps to Finalize Policy

Consult further during focus groups with stakeholders and interviews with key informants on emerging directions.

14. Income Verification and Rent Calculation

a) Background

The legislation assigns the responsibility for financial testing of RGI households, including income verification and rent calculation, to the service manager. The service manager may delegate this responsibility to a third party. The City of Ottawa must determine who will be responsible for income verification and rent calculation at various times of the process (e.g. at application, occupancy, annual). This local decision needs to be co-ordinated with local decisions made on other aspects of financial testing and co-ordinated access. (Legislative Reference: SHRA section 66)

b) Service Manager Options

1. Choose to manage the role of income verification and rent calculation

2. Delegate the role of income verification and rent calculation to The Registry

3. Delegate the role of income verification and rent calculation to another community agency

4. Delegate the role of income verification and rent calculation to different parties (e.g. housing providers, The Registry), depending on the stage of the review process (e.g. at application stage, after the applicant is housed)

c) Stakeholders' Preferred Options

All responding stakeholders selected Option Four.

d) Additional Information from Other Jurisdictions

In its survey of Service Managers, ONPHA found that:

· 87% have delegated or are delegating income verification and rent calculation to housing providers

· 13% are centralizing this function

The City of Toronto, York Region and Waterloo Region are delegating the function to providers. The Region of Waterloo has produced a manual to assist providers with this function and is conducting regular training. In all provinces consulted, housing providers conduct income verification and rent calculation on their own units, with periodic monitoring by the province/housing authority. Most provinces maintain a "help desk" to act as a resource for providers. In major US jurisdictions surveyed, providers conduct income verification and rent calculation on their own units.

e) Emerging Directions

There is unanimity on this issue. All respondents support providers conducting income verification and rent calculation, with the City providing training and periodic audits for accuracy. There appears to be no financial or other benefit to having the City or another party involved due to the administrative burden and cost.

f) Next Steps to Finalize Policy

Consult further with key informants and seek concurrence during focus groups with emerging direction.

15. Internal Review of Decisions Regarding RGI Eligibility

a) Background

The legislation describes how RGI applicants and households may appeal an RGI or access decision they feel was unfair. Decisions which may be appealed by an RGI applicant or household include:

Household ineligible for RGI assistance
Household ineligible for special needs housing
Type of accommodation in which the household has been place on the waiting list
Category into which the household has been assigned on a waiting list
Amount of geared-to-income rent payable by household
Deferral of geared-to-income rent payable by household

The City of Ottawa must decide how it will administer the internal review or appeal process. This local decision needs to be co-ordinated with local decisions made on other aspects of financial testing and co-ordinated access. (Legislative Reference: SHRA sections 82 & 83, O. Reg 298/01 sections 57 and 58)

b) Service Manager Options

1. Choose to handle all reviews

2. Assign all internal reviews to housing providers (either staff or board as appropriate)

3. Assign all internal reviews to a committee consisting of representatives from housing providers, service manager and possibly The Registry

4. Assign different types of internal reviews to different parties, as appropriate

c) Stakeholders' Preferred Options

The following provides a breakdown of the preferred options identified by type of stakeholders.

Stakeholder	Option 1	Option 2	Option 3	Option 4
Co-operatives	-	5	1	3
Non-Profits	-	3	4	2
Sector Organization	-	-	-	1
Service Agency	-	1	3	4
The Registry	-	-	-	1

d) Additional Information from Other Jurisdictions

In its survey of Service Managers, ONPHA found:

· 52% are delegating internal reviews for RGI decisions to providers, at least for an interim period

· 24% have decided that internal reviews should remain with the Service Manager

· 19% are establishing committees to do reviews

· 2% (one service manager) are delegating the responsibility to the LHC

Some of the specific approaches among Service Managers include:

In Peel Region, all reviews will be handled by the Service Manager, specifically the Commissioner of Housing. York Region's process will also be handled by the Service Manager. The Region is considering an approach involving housing providers, who would be responsible for information flow to and from the Service Manager. The provider would ensure that completed review forms are forwarded to the Region. Decisions made by the Region would then be returned to the tenant via the housing provider. This method would help to ensure a strong tenant/housing provider relationship.

Waterloo Region has established a Social Housing Advisory Committee comprised of housing providers, Regional staff, Councilors and tenants to advise on all housing matters. A sub-committee of SHAC will hear requests for internal reviews on access and RGI decisions. The City of Windsor has left the review process with providers and has asked that each provider develop processes and procedures to accommodate the requirements.

In terms of other provinces, public housing tenants in units operated by housing authorities can appeal through administrative review committees which are usually comprised of senior department staff members. In BC, non-profits and coops have the autonomy to establish their own review process; however, the guidelines are set out in operating agreements between the housing providers and BC Housing

In major US jurisdictions, the local housing authority regulates who handles RGI review and appeals processes. In most cases, appeals are heard by staff, but in Boston they have set up panel comprised of staff and residents of the housing authority. Similarly, in Chicago, appeals are heard by a panel consisting of the property manager, head office staff and residents. The majority of the panel must be residents.

e) Emerging Directions

This policy area may be the most difficult of all in which to reach consensus. It is interesting to note that 9 stakeholders selected Option Two, 8 stakeholders selected Option Three and 11 stakeholders selected Option Four. There are a variety of opinions from all sides on the best approach to reviews, often accompanied by well expressed and reasonable arguments. Even the ONPHA survey showed a wide variation of approaches across the province.

Not one stakeholder expressed the view that the Service Manager should handle reviews. It is interesting to note, however, that some of the other large Service Managers across the province are doing just that. They believe they are in the best position to make a fair and impartial judgment on such matters and they will be seen as impartial by all involved.

Many housing providers believe that they are in the best position to handle reviews involving tenant-related decisions, as they are closest to the situation and have the strongest understanding of the issue. Many community-based support and advocacy groups, as well as some providers, believe there needs to be an impartial external committee with mixed representation. Some would like to see tenants included on such a committee. Some stakeholders believe there should be different types of review structures and processes, depending on the issue.

It is clear that this issue requires more discussion and that it is premature to suggest a policy direction at this time. There are a number of principles, however, which do appear to be important to stakeholders in establishing a review process for decisions regarding RGI eligibility. These include:

· fairness, transparency and openness

· easily understood by all parties

· practical and easily accessible to the individual

· timely

· considers language and literacy needs of all parties

· "one size does not fit all"--review process may need to differ for large organizations vs. small ones with limited resources

· there needs to be appropriate process for different types of reviews (especially applicant/waiting list-related reviews and tenant-related reviews)

f) Next Steps to Finalize Policy

The issue of internal review of decisions regarding RGI eligibility should be discussed in detail during focus groups and greater consensus achieved regarding best approach for supporting principles identified above. Additional research will be conducted on other appeal processes in place at the City and interviews with key informants will be conducted.

D. Co-ordinated Access Review

Below we review stakeholder comments on the issues pertaining to the Coordinated Access System in the City of Ottawa.

16. Refining Existing Coordinated Assess System

a) Background

The legislation requires that service managers establish and maintain a common waiting list system to co-ordinate application and assessment processes for RGI applicants. Currently, The Social Housing Registry maintains a coordinated access system in Ottawa on a purchase-of-service basis with participating housing providers. The Registry is a legally distinct entity, established by local housing providers and community-based housing groups in 1997. A Board of Directors, comprised of housing providers and community based organizations, oversees the operation of The Registry.

The City of Ottawa may designate the responsibility for establishing and maintaining a common waiting list system to a third party. It is the City’s intent to build on the success of the existing system operated by The Registry and to refine the service model for co-ordinated access to meet legislative requirements and community needs. This local decision needs to be co-ordinated with local decisions made on other aspects of financial testing and co-ordinated access. (Legislative Reference: SHRA sections 68, O. Reg 298/01 section 35-44)

b) Service Manager Issues

Legislative requirements to be examined include the system’s ability to:

· produce subsidiary waiting lists for individual housing providers at least once each calendar month

· include all households applying for RGI, including identification of housing project preferences

· rank applicants as specified in subsection 68 (5) of the SHRA

· include other information on households applying for RGI assistance, including name of members of household, address, special priority and eligible size and type of unit

· provide notice to applicants and housing providers

· follow the rules for the centralized waiting list as specified in the regulations

Community needs to be examined include:

· representation on The Registry board of directors

· maintaining relationships with applicants

· location, IT and other issues identified items 17 to 19 below

c) Summary of Stakeholder Comments

The comments received indicate that most respondents are quite satisfied with the operations of the Registry and the Registry believes it meets most of the requirements of the legislation.

There are some concerns identified by some stakeholders. These include:

· concerns about the level and range of information available to applicants about housing choices;

· concerns about the composition of the board--specifically a desire by several stakeholders to have one or more tenants and possibly applicants on the board;

· a desire to see a "transfer list" developed for overhoused, underhoused and other transfers;

· a desire for greater availability of French language services;

· an interest in an electronic application process;

· a view that the Registry should not include supportive housing

d) Next Steps

The consulting team will continue its assessment of the Registry's compliance with the requirements of the legislation. The issues and concerns identified above will be explored through the focus group sessions and through further discussion with the Registry, HSAG and City of Ottawa staff.

17. Governance Structure and Accountability Framework

a) Background

There is no formal agreement between the City of Ottawa and The Social Housing Registry in place at this time. The City of Ottawa plans to develop a governance structure and accountability framework that will form the basis for relationships between The Registry, City of Ottawa (as service manager) and housing providers. The City must implement a fully operational common waiting list within one year from the transfer date (April 1, 2003). (Legislative Reference:

SHRA section 68)

b) Membership and Representation

Currently, members of The Registry must be either:

· housing co-operatives

· local housing corporation

· municipal housing provider

· private non-profit housing providers

· incorporated community organizations representing the interests of applicants to RGI housing

The members of the Board of Directors of The Registry are currently elected on an annual basis. The Board is comprised of between 5 and 12 directors depending on the number of members in each membership category. The number of positions on the Board available to each membership category is:

· housing co-operatives (maximum of 3 directors)

· local housing corporation (1 director)

· municipal housing provider (1 director)

· private non-profit housing providers (maximum of 5 directors)

· incorporated community organizations representing the interests of applicants to RGI housing (maximum of 2 directors)

A formal agreement & accountability framework between The Registry and the City of Ottawa needs to be developed.

c) Summary of Stakeholder Comments

Most stakeholders find the governance structure of the Registry satisfactory. Several stakeholders and the Registry itself recognize the need for a formal accountability framework with the City as Service Manager. This can be achieved through a contractual service agreement. Some of the other relevant points raised include:

· advocacy groups should continue to be on the Board and on any appeals committee;

· the Registry should operate at arms length from the City and the City should require only that the Registry fulfil the relevant legislated responsibilities it is being delegated by the City;

· at least one seniors-only private non-profit should be represented on the Board;

· any extra costs required to meet legislative requirements should be met by the City and passed on to the Registry through providers, so that they can maintain their direct linkage with the Registry;

· the Registry recognizes that additional legislative requirements will require additional workloads for its staff;

· consideration should be given to a maximum term of 2 years for directors, there should be rotation of representatives and a clearer definition of the appointing group and who is eligible for appointment.

· directors should serve for 3 years, with governance by representation.

d) Next Steps

The consulting team will continue its assessment of the Registry's governance structure and accountability framework. The issues and concerns identified above will be explored through the focus group sessions and through further discussion with the Registry, HSAG and City of Ottawa staff.

18. Mandate of The Registry

a) Background

The existing letters patent and by-laws identify the mandate and objectives of The Registry. The City of Ottawa plans to review the mandate and responsibilities of The Registry as part of the refinement of the existing system. The City must implement a fully operational common waiting list within one year from the transfer date (April 1, 2003). (Legislative Reference: SHRA section 68 and O. Reg 298/01 sections 35-44)

b) Current Mandate and Areas of Responsibility

The current mandate and areas of responsibility of The Registry which are under review are as follows:

· The mandate of The Registry is to provide one-stop services to applicants. For housing providers, The Registry manages the application process for RGI units and places applicants on a waiting list according to a modified chronological system.

· The objects of The Registry are to assist persons seeking RGI housing and housing providers through:

o the establishment of a central registry listing details of such housing

o development of a common application form and a co-ordinated means of assessing eligibility

o maintenance of waiting lists for participating housing providers

· The Registry also is responsible for:

o maintaining statistical data on demand for RGI housing

o ensuring information about social housing options in the City is available

c) Summary of Stakeholder Comments

Most stakeholders are satisfied with the mandate of the Registry. The Registry itself feels it meets the legislative requirements under Bill 128 in this regard. Most stakeholders support making only the most minimal changes that might be required to fully comply with the new legislative requirements. The point was emphasized again that a contract or service agreement with the Service Manager is a suitable vehicle for identifying and refining exact requirements and responsibilities. One stakeholder felt the City as Service Manager should oversee and manage the Registry, but most feel there should be an arms length relationship.

e) Next Steps

The consulting team will continue its assessment of the Registry's mandate. There do not appear to be many issues remaining in this regard to explore in the focus group sessions and through further discussion with the Registry.

19. Location of The Registry

a) Background

The Registry is currently located on the 5^th floor, at 2197 Riverside Drive, Ottawa, Ontario K1H 1A9. The City of Ottawa plans to evaluate the appropriateness of the current location of The Registry, including need for satellite offices.

b) Service Manager Options

A number of locations for The Registry may be considered by the City of Ottawa, including:

· current location

· City of Ottawa municipal building location

· central location (i.e. current or other location), plus satellite offices

· City of Ottawa Housing Branch office (1595 Telesat Court in Gloucester), plus satellite offices in existing OW or community agency sites

c) Summary of Stakeholder Comments

There is widespread agreement among stakeholders and the Registry itself that the location should be based on a number of principles, as follows:

· there should be a diverse range of locations for application, accessible by public transit where possible;

· locations should be serviced by informed individuals knowledgeable about the housing system;

· there should be a central location that maximizes accessibility for in-person visits, is convenient for staff and suitable for administrative purposes and related central functions;

· the central location should be separate from the City and, if possible, Ottawa Housing, to emphasize the arm's length position of the Registry and to avoid confusion in the public about its role

· the Registry should make its own decision about its ultimate location

· the cost of centralized office space should also be a consideration to minimize fees to members

The current system appears to fulfil most of the above conditions, with individual providers acting as satellite offices at no extra cost. They are located across the city, often with direct access to public transit, and are staffed by persons knowledgeable about the housing system; all at little or no cost to the City.

The current central location of the Registry appears to function well in view of the heavy traffic on site; nevertheless, there is concern that the location is closely identified with Ottawa Housing and that ultimately a separate location would better support the arm's length role of the Registry. When the current lease is nearing renewal, the Registry should examine options that provide similar benefits at similar cost while providing separation from the Ottawa Housing location.

d) Next Steps

During the next stage of consultation, the consultants will seek concurrence with stakeholders that the current system and current central location are suitable. This will be done through the focus groups and discussions with HSAG, City of Ottawa staff and The Registry.

20. Information Technology

a) Background

The Registry utilizes a customized Lotus Notes database system to maintain the waiting list and provide direct access for member providers. The City of Ottawa plans to assess the current information technology system’s ability to address service delivery issues.

b) Service Manager Options

A number of IT options may be considered by the City, including:

· maintaining existing Lotus Notes database and upgrading system as required

· purchasing another systems utilized by other service managers (i.e. Yardi)

· exploring a web based option

c) Summary of Stakeholder Comments

Virtually all stakeholders find the current Lotus Notes system quite workable. The Registry finds it meets its needs and can be modified to meet all new requirements at an affordable cost. Exploring a web based option appears to be a suitable approach in view of the potential advantages across the system.

There is widespread support among stakeholders for allowing the Registry to make its own decision on information technology systems. It must be kept in mind, however, that the City, as Service Manager, has a responsibility for ensuring the system can meet legislative requirements, is suitable for providers and will facilitate any accountability and reporting requirements between the Registry and the City; thus, it cannot be entirely divorced from decision. In addition, the City may want to use the waiting list system for other purposes, such as for housing need analysis or to determine the impact of specific policy decisions on the waiting list for social housing. This is another reason why the City’s requirements should be considered in selecting an IT system for waiting list management.

d) Next Steps

Further discussions with The Registry and City of Ottawa staff are required to ensure that the City’s needs are being met with the current system. Further consultation with housing providers and other community agencies is not anticipated at this time.

21. Funding of The Registry/Fee Structure

a) Background

The legislation gives service managers the responsibility of establishing and maintaining the co-ordinated access system. It is anticipated that benchmarked costs will be identified for funding purposes. This may have an impact on the current Registry fee structure.

b) Service Manager Options

The City plans to examine the existing fee structure of The Registry and compare it to the benchmarks identified by the Social Housing Services Corporation when they are provided.

c) Summary of Stakeholder Comments

Most providers (and certainly the Registry itself) expect that ongoing costs of operating the Registry will increase due to additional legislative requirements. The Registry points out that there will also be one-time "start-up" costs to put any new systems in place. Naturally, most providers are already concerned about meeting the existing cost of operating the Registry and are apprehensive about any new added costs.

The Registry and several respondents noted the key point here--any permanent adjustments in fees and charges must await the release of benchmarks so that the impact of the new funding model is known. At that time, final decisions can be made about fee adjustments.

In the interim, it is important to identify new requirements, any additional resources needed at the Registry to meet these requirements and any additional costs involved (both start-up and ongoing). A service agreement should be signed between the Registry and the City for the delivery of these services. Any additional costs should be recognized and paid by the City on an interim basis until such time as the benchmarks are released and a final financing formula can be determined.

Most providers emphasize the importance of maintaining the Registry's arms length position; accordingly, it is important that payment of any increased annual operating costs should go from the City through providers to the Registry. One time start-up costs could be paid directly from the City to the Registry as part of the social housing devolution process.

d) Next Steps

The consulting team will work with The Registry and the City to identify any additional requirements and the resources necessary to meet these requirements. The key elements of a service agreement between the City and the Registry will be identified, including an identification of the services provided by the Registry, a suitable funding level or fee for these services, and how additional costs will be paid. Once the benchmarks are released, The Registry, the City and the housing providers will need to work together to determine how the payment schedule needs to be adjusted.

22. Review of Other Service Delivery Issues

a) Background

The Registry has a common application form in place and applicant accessibility process in place. The City of Ottawa plans to review the common application form and applicant accessibility to ensure that they meet legislative requirements and community needs. (Legislative Reference: SHRA section 68)

b) Service Manager Responsibilities

The existing common application form is currently under review to ensure that legislative requirements are met.

The existing processes in place to address applicant accessibility include:

· bilingual service in both English and French

· assistance to people who wish to apply for an RGI unit by providing:

§ information on basic eligibility

§ assistance completing application form

§ general information on social housing options in the City

§ information on and referral to community organizations representing the interests of applicants to non-profit housing and other community resources

There is an ability to apply directly with a member of The Registry; however the onus is on the applicant to forward a completed application to The Registry.

c) Summary of Stakeholder Comments

A number of suggestions have been made for improvements to the application form. The Registry should consider these suggestions as it works on revisions to the form to meet legislative requirements. Several stakeholders indicated a need for more help to applicants in filling out form (e.g. disabled, seniors, linguistic support). Methods of delivering this help should be examined. The Registry should confirm that it complies with bilingual requirements. The idea of a personal telephone ID number might be explored, as well as ways to provide suitable information on each project so that applicants are more selective in deciding on preferences.

d) Next Steps

Some of the comments will be explored more thoroughly at the focus group sessions and discussions with The Registry, HSAG and the City of Ottawa staff.

23. Modified Units Without Supports

a) Background

The Registry currently maintains the waiting list for modified units without supports as part of the existing co-ordinated access system. The legislation states that these units will be filled by a “lead agency”. The Province has not yet appointed the lead agency. Until they do, housing providers are responsible for filling these units from their waiting lists and setting policy for this list that complies with the provincial regulations. A number of concerns have been raised regarding the implementation of this policy. First, many housing providers are finding it difficult to fill their modified units. Second, households in need of modified units may be forced to travel from one provider to another to apply for housing.

The City of Ottawa may decide to exercise its authority to allow housing providers to delegate access to modified units to the co-ordinated access system. (Legislative Reference: SHRA section 63 and 64)

b) Service Manager Options

The City of Ottawa is reviewing a number of options for modified units without supports:

1. Housing providers keep responsibility for access to modified units

2. Allow housing providers to delegate access to modified units to The Registry

c) Stakeholders' Preferred Options

The following provides a breakdown of the preferred options identified by type of stakeholders.

Stakeholder	Option 1	Option 2
Co-operatives	4	4
Non-Profits	3	4
Sector Organization	-	2
Service Agency	1	4
The Registry	-	1

d) Emerging Directions

The majority of stakeholders support leaving this function with the Registry. Many point out that persons with disabilities have limited mobility and benefit by being able to apply to one central location where they can identify all possible locations with suitable units. This would appear to be the most important factor in resolving this issue.

e) Next Steps to Finalize Policy

Consult further during the focus groups on the emerging direction.

Organization		Contact
Non-Profit Housing Providers
1. Asher Christian Seniors Inc.	Nick Greco
2. City Living	Margaret Singleton
3. Community Works NPHC	Donna Lee Wilkinson
4. Cumberland Housing Corporation	David Lewis
5. Gloucester NPHC	Brian Ganim
6. Goulbourn Non-Profit Housing Corp	Grant Cousins
7. Inuit Non-Profit Housing Corporation	M. Komendat
8. Nepean Housing Corporation	Janice LaFontaine
9. Rideau Non-Profit Housing Inc.	Frank Sisson
10. Ottawa Housing Corporation	Denis Michel
11. Township of Osgood NPHC	Bonnie O’Brien
12. West Nepean Ecumenical Residential Projects (Hamer House)	Kimberly Whitty
Co-operative Housing Providers
13. Cardinus Housing Co-operative Inc.	Ken Lawson
14. Carpenter Co-op	Curtis Johnson
15. Cartier Square Co-op	John Pyl
16. Conservation Co-op (3 separate responses)	Maggie Fleming, Kim Lavoie, Lois Squares
17. Coop Voisins	Amanda Shaughnessy
18. Dobbin Co-op	Anne Marie Mason
19. Eagelson Co-op	Michelle Bainbridge
20. Glenn Haddrell Co-op	Margaret Walesiak
21. Mario De Giovanni Housing Co-op	Torrie Masterson
22. Tannenhof Co-operative Homes	Andrea Burns
Sector Organizations
23. Cooperative Housing Association of Eastern Ontario	Brian Gifford
24. Ottawa Social Housing Network – ONPHA Member Organizations	Debbie Barton
Co-ordinated Access
25. The Registry	Ishbel Solvason
Service Agencies and Housing Advocates
26. Action-Logement	Rosine Kaley
27. Centre de resources communautaires de Cumberland	Claude Crustin
28. Centre for Equality Rights in Accommodation	Sherrie Tingley
29. Centre de resources communautaires Overbroke-Forbes	Simone Thibault & Daniele Hamonic
30. Children’s Hospital of Eastern Ontario – Immune Deficiency (Acquired)/G.I. Clinics	Dianne Stevenson
31. Disabled Persons Community Resources	Teena Tomlinson
32. Housing Help	Trudy Sutton
33. Nepean Community Resource Centre	Kim Bulger
34. Ottawa Salus Corporation	Sandra Biegler
35. Pinecrest-Queensway Health and Community Services	Marilyn Mills, Sue Merrill
36. Sandy Hill Community Health Centre	Patricia Harewood
37. Supportive Housing Network & Options ByTown	Lorraine Bentley