1 SILC NET presents... a national teleconference and webcast. Expanding the Availability of Accessible Housing. Presenters: Ann Denton and Sarah Andre. >> OPERATOR: Good afternoon everyone, and welcome to the expanding the availability of accessible housing teleconference. Today's host will be Tim Fuchs. All participants will be muted. If you have a question, you may press 0 and then 1 on your telephone keypad. Questions will be answered in the order it was received. Now, without further delay I will turn the call over to Mr. Fuchs. >> TIM: Thank you, Matt. Good afternoon and welcome to the webcast Expanding the Availability of Accessible Housing. I'm Tim Fuchs, operations director at the National Council on Independent Living. Today's teleconference and webcast is presented by the SILC NET, and CIL NET for Centers for Independent Living. IL NET is operated by the Independent Living Research Utilization program at Memorial Hermann/TIRR in partnership with the National Council on Independent Living or NCIL and the Association of Programs for Rural Independent Living, APRIL. Substantial support for the presentation of this presentation was provided by the U.S. Department of Education, Rehabilitation Services Administration under a grant. No official endorsement of the Department of Education should be inferred. I 2 need to inform you that we are recording today's call and it will be archived. Also as Matt indicated, all of your telephone lines are muted and you will be able to ask questions by simply pressing 01 on your keypad to put you in the queue and our Q. and A. sessions today are scheduled for approximately 3:30 p.m., 4:00 p.m. and then again at 4:20 p.m. For those of you that are participating by webcast, you can ask questions, too. There are two ways to do that. The first is just to use the ask a question feature on your screen or E-mail me directly at tim@ ncil.org. And I'll relay all those questions live on the call. The materials for today's call including the PowerPoint presentation and the evaluation form are located on our website at -- I'll read this twice -- www. ncil.org/training/accessiblehousingmaterials.html. For the PowerPoint presentation if you have not already accessed that and the evaluation form -- Take a moment after today's call to fill out the evaluation form. It only takes you a few moments to complete and it is important to us. We review every single evaluation and they are tremendously helpful to us in learning what you all think of our presentations and what you need and we take them seriously when we prepare for our future trainings. Today's presenters are both experts on systems level strategies to expand the availability of accessible affordable and integrated housing for people with disabilities. Both are Advocates for Human Potential Ann Denton and Sarah Andre. And also with us today is Darrell Jones of ILRU. I want to thank them all for their hard work in preparing today's presentation. I want to welcome them to the call. 3 Without any further ado, I want to turn it over to them and first today will be Ann Denton. Ann... >> ANN: Good afternoon and I appreciate the opportunity to present materials with Sarah Andre and we would like to walk you through what we're going to present. In the first slide labeled introduction you'll see there are four major sections to this presentation. First of all, we're going to talk about where the money is. We'll talk about resources for housing and that will take us a little bit of time, and then we will turn to an even more important question, which is once you know where the money is, how can you engage willing partners, people who have the money, who control the resources, how can we make it possible for them to say yes to what we want. And then finally we're going to do a session -- a section on how to interact with those good partners. Next slide is our learning objectives. By the time we're done, Sarah and I, you'll be able to name three major sources of federal or state housing funding, identify collaborative strategies you might use, have an idea about how to proceed in terms of the SILC plan, identify federal and state housing systems, recognize potential partners and talk about how you can use this information to do effective plannings. Next slide. In terms of expanding resources, the first topic we wanted to cover is where is the money? And what we need to tell you about that is the money comes from many different places and most of it is federal, but it may look like it's state money and look like local money, but most of the primary sources of dollars are federal and we're going to talk about those. Also we're going to talk a little bit about state 4 resources, state specific resources. Next slide. We're going to start by looking at HUD programs and then opportunities from the Department of Agriculture and finally the tax credit program. What we're going to talk about with HUD resources -- HUD is the source of most of the money in a community, either through their consolidated plan programs or through public housing authorities. And the HUD resources covered by the consolidated plan include the HOME program -- I'm sorry, I skipped way ahead. We're on the slide of expanding resources, where is the money. And I want to talk about HUD resources governed by the consolidated plan. Within that we're going to talk about the HOME program and then we're going to talk about working with public housing authority -- public housing authorities. >> SARAH: This is Sarah Andre just chiming in here. In addition to talking about HUD resources, we'll talk about low income housing tax credits which are actually administered by the I. R. S. and then as Ann mentioned we'll be going on to talk about the Department of Agriculture and some of the funds that they have available for housing. >> ANN: So back to HUD. The consolidated plan is a planning process that local communities and states embark on. It's a three to five-year planning process, but every year funders are required to do an annual update. You can also look at performance information from HUD about how communities are doing. You can request major changes in the consolidated plan when a new three or five-year plan is in the works. The thing to remember about the 5 consolidated planning process is that they are required to seek out and use public input. Next slide -- and this is the consolidated plan programs. We're going to tell you the consolidated plan governs the programs that are on the slide, the HOME program, the CDBG program, Emergency Shelter Grants, HOPWA, Housing Opportunities for People With AIDS, Housing Choice Vouchers for the state. >> SARAH: The main thing we're going to focus on today are the programs. One of the ones that is the easiest to use and as you're just getting familiar with programs, we encourage you to focus on that program. If you move to the next slide entitled HOME investment partnership programs. I'm going to tell you a little bit about the HOME program. The HOME program can be used for four major activities, and once you get the hang of these, I promise they are a little bit easier to comprehend. The first one is owner occupied housing assistance. That is assistance to people who own their own homes already. The second major program under HOME is rental project assistance. If you are developing rental housing, those funds can be used for that. The third major activity is homebuyer assistance, helping people purchase homes either through down payment assistance or closing costs assistance. And then the fourth major activity under the HOME program is tenant-based rental assistance. And that is basically what it sounds like. It is providing vouchers to people to go out and rent apartments. HOME funds, as Ann mentioned earlier, are available from both the 6 state and your units of local government. HUD allocates HOME funds to what they call participating jurisdictions, basically, large metropolitan areas, areas that meet a population threshold and they use a formula that factors in things like the area median income, the number of people in poverty, the total population, kind of typical demographic factors in order to decide how much each participating jurisdiction, which is usually a city, a large metropolitan county, how many HOME funds they get. Those funds then trickle down to that unit of local government. The rest of your state, and if you're familiar with the continuum of care, they don't call it a balance of state, but basically each state also gets HOME funds -- the state then allocates to areas that are not participating jurisdictions. So by way of example, that would be a rural area outside of a large metropolitan county. You would go to the state for HOME funds. All HOME funds can be used to assist people with disabilities, and the two activities that are particularly helpful and that both Ann and I have seen used a lot that assist people with disabilities in finding housing are the tenant-based rental assistance program and owner occupied housing. So let's go to the next slide and I'm going to talk about owner occupied housing assistance. For those of you that are familiar with the term median family income, that's basically the middle income for an area. So all of these programs are targeted towards people at a certain level of the area median family income, and owner occupied housing assistance can be used to provide rehabilitation assistance to households that are 80 percent or less of the area's median family income. 7 And usually owner occupied housing assistance is used for a number of things, typically things like weatherization, putting on new roofs, fixing foundations, major home repair for people who are low income. One of the really wonderful things that we've seen done with these funds is to modify homes for accessibility. So providing grab bars and accessible showers in the bathroom, remodeling the home to put a ramp in, that's been done all over Texas and it's been very successful in helping people who have disabilities and are on lower incomes make their homes accessible so that they can stay in their home. Another example of the way the HOME program can be used is tenant-based rental assistance. So let's go to our next slide and talk briefly about that. Tenant-based rental assistance is just what it sounds like, basically. It's rental assistance that stays with the tenant. It's very similar to the housing choice voucher program. Lots of you know that as Section 8. And the tenant goes through an application process, and then receives a voucher and then can go rent an apartment or home that qualifies for the program wherever he or she chooses. The difference in tenant-based rental assistance compared to the housing choice voucher program is that it's time limited. It's really -- the funding is limited to only 24 months. And so it's not a long-term solution to affordable housing. However, what's excellent about it is that it can help a person bridge that gap. We know that waiting lists for Section 8 or the housing choice voucher program are very, very long. And this will give someone two years of assistance while they were on the regular PHA's waiting list. So that's a way that these funds can be used to bridge to the housing choice voucher 8 program. Ann is going to talk a little bit about public housing authorities now, so I'm going to turn the microphone over to her. >> ANN: Well, the beautiful thing about public housing authorities is they are one of the best ways to provide regular and integrated housing. PHAs control the bulk of the resources that HUD sends to communities for affordable housing, and the housing choice voucher program also known as Section 8 as Sarah said, is targeted to people with lowest levels of income. We are all thinking about a population that may be on an SSI level of income and public housing authority resources are targeted for that income group. Let me back up and tell you a little bit about what a public housing authority is. In order to be a public housing authority, the entity, number one, must be certified as such by HUD and then they must operate their own housing units or the housing choice voucher program or both. So you can tell a housing authority by their participation in those two activities. Next slide labeled HUD funding, working with public housing authorities. I just said all that. Please forgive me. The next slide, public housing resources. There are many things that public housing authorities can do. Beyond the two that I've already mentioned, which is housing choice voucher and operating their own housing units, they also have in the recent past participated in something called the home fix program. This is a program where they are reducing the density in their own housing units. So it's housing they operate. 9 >> SARAH: You may have seen that if not in your own community, in the news where public housing projects have been torn down and then rebuilt in a more of a maybe mixed income or a mixed use way. (Inaudible). >> ANN: Almost high rises to cottages. Not quite that clear, but almost. Then there are -- it's possible to use -- they have some discretionary uses for housing choice voucher programs. They can set aside housing choice vouchers for people with disabilities. They can use Section 8 housing choice voucher rent subsidies for home ownership. And those of you who are familiar with the home of your own program, this is something that can be used to support home of your own. They can use up to 20 percent of housing choice voucher for project-based rental assistance. Let me back up and say again a little bit about what different rental assistance are. Tenant based rental assistance is attached to the tenant. The tenant can take it wherever they choose to live. Project-based rental assistance is attached to a particular housing unit. So it helps fund the unit and make that unit affordable, but if the tenant moves, the assistance stays with the unit. One of the reasons that's important for people with disabilities, is it's possible to use that authority that a housing authority has to project ways some of its assistance to do -- to support integrated development of affordable housing. You can use project-based assistance -- let me give you an example. The state of Georgia took some of their rental assistance that they had and they attached it to a maximum of 20 percent of the units, the projects that were already being developed through their HOME program. So they had a (inaudible) projects that were close to opening and took some 10 of their rental assistance and attached it to those units so that 20 percent of the units then will be affordable to someone on an SSI income. It was a fairly quick and easy way to make an inroad into affordable housing development. Moving to the public housing authority plan -- (inaudible). The consolidated plan which we've already talked about requires public input. The nice thing about public housing authorities is that they also have plans that require public input. It's possible for the CILs to provide written comment and testimony to PHA boards to make the case that people with disabilities need specific assistance from the public housing authority or want to be included. One of the best things to ask a public housing authority is for them to apply for what they call discretionary programs such as the mainstream housing vouchers. The mainstream housing vouchers are vouchers that are set aside for people with disabilities and that housing authorities can apply for. Most housing authorities don't do that unless we ask them to. So it's one of the things we can ask for. Another thing that we can ask public housing authorities to do is create a local preference for people with disabilities. Many years ago and some of the more educated listeners on the call will remember that public housing authorities had automatic federally mandated preferences that people with disabilities were an automatic preference. About probably ten years ago now that requirement went away and public housing authorities were free to decide whether or not to set 11 any local preferences or what kinds of preferences they would like to set. So some public housing authorities still retain a preference for people with disabilities, but many of them have done away with preferences altogether. But the important point here is that it's one of the things that can be asked for, the CILs can ask for that or the SILCs can provide information to support that at the state level. >> SARAH: It's very important I'd like to add that you get a copy of your local consolidated plan and your local public housing authority plan, find out what's in it and that's how you can then begin to strategize about what you'd like to ask for. All of these groups have to seek input on their plans on an annual basis, and it's very easy to provide written comment and testimony to your PHA board or just to back up a little bit to whoever is having a consolidated plan hearing at your local housing jurisdiction. >> ANN: So that sort of concludes our section on public housing authorities, and I'm going to turn it back over to Sarah to talk about tax credits. >> SARAH: Sure. I really wish I could see a show of hands on who knows anything about the low income housing tax credits program, because this is one of the largest sources that we have for housing development, but it is also one of the most confusing unfortunately. So I'm going to give an overview. Fortunately we have a Q. and A. session coming up. Basically as I mentioned earlier, the low income tax credits program is actually administered by the I. R. S. Section 42 of the I. R. S. code, for those of you who really like the Internet, provides the 12 statutory authority and the rules for how low income housing tax credits are allocated. It basically is the I. R. S. leaves it up to state housing finance agencies or sometimes it's your state Department of Housing and Community Development to lay out rules for the state in terms of how they want to allocate credits. Because the program is so confusing, it is also really competitive. The best thing to do if you're thinking about getting into tax credits is to go ahead and hire a consultant. A consultant -- at least for your first time around -- will be able to help you navigate what your local state wants, what the best strategy is with regard to scoring and also help with financing because it is complex. Just to give you a taste of how this program works, basically a developer is awarded tax credits through a competitive process and then sells those tax credits to a private entity, a corporation like -- I'm just going to throw out a large company -- Philip Morris, for example, although I think they have a new name now. I'm a little behind the curve, but a large entity like that that has high profits that will have a high tax liability. So they buy tax credits to offset what they owe the I. R. S. and that money that they purchased the tax credits with then goes into the housing development making it more affordable. The rents can be lower. The tax credit program can be used for new construction. It can be used for rehab. It can also be used for acquisition and rehabilitation of old housing units. And I've seen almost every configuration in tax credits -- high rises, condos, single-family type houses being built as rental property as well as just standard apartments that we're all used to. 13 Some of the -- as I mentioned, the I. R. S. lays out the requirement. So let's go to the next slide, low income housing tax credit project requirements. Basically, at the federal level, every single tax credit project has to meet one of these two income requirements, either 20 percent of the units in a project are rent restricted and occupied by people who are 50 percent or less of the area median income. For example, if you had 100 units, 20 would have to be for households earning 50 percent or less; or 40 percent of the residential units are rent restricted and occupied by individuals whose income is 60 percent or less of the area median income. And in that same example of 100 units, you'd have 40 units that were occupied by people whose income is 60 percent or less of the median area income. Now, that's the minimum that you have to do. Most states have made it much higher than that. For example, in Texas 96 percent of your project must be income restricted. Also I'd like to point out -- I just mentioned 50 percent of area median income and 60 percent of area median income. As Ann mentioned earlier, when we're talking about people with disabilities who live on a fixed income like SSI and SSDI, often their incomes are much lower than even that. The tax credit projects are not naturally affordable to people in that lowest income group, but there are a lot of things that you can do as an advocate to make your local projects more affordable and more accessible to persons with disabilities. And we can go over the next slide, I'm going to cover some more of the basics. This is low income housing tax credit project requirements continued. Properties that receive tax credits have to remain affordable 14 for 30 years. Many states have made that as much as 40 or 50 years. Tax credits are not targeted to any kind of special needs groups necessarily. They are not targeted to people who are homeless or people with disabilities or people with any other special needs. Most states have done some kind of targeting within their point structures, and I'll talk about that in a minute. And then just like the consolidated plan and the public housing authority plan, every state that allocates credits must hold annual hearings and public comment periods for what's called the qualified allocation plan. And most people call that the QAP. So the QAP is really the key in terms of how your state is going to set out its local preferences for either income targeting or special needs populations or a variety of other things that they may offer points for projects that are located in certain areas of the state, in certain areas of the city, projects that have funding from local governments as well as tax credits, everyone's QAP is a little different and you'll need to find your QAP for your state and then go ahead and see what they've said is important to them and then talk about what you'd like to see changed. This is not on our slide, but I'd like to give you a website where you can get your local QAP and we can also repeat this during the Q. and A. session. It's the website for a company called Nova Braddock which is a large accounting firm and they have a lot of information about tax credits. It's www.novoco.com. Now I'm going to turn it over to Ann for a little bit about the Department of Agriculture. >> ANN: Yes, so far we've been talking about the HUD consolidated 15 plan, the HUD public housing authorities, and then Sarah talked about low income housing tax credits. Those are all excellent sources of housing funding for people with disabilities. But all of them pretty much that we've been talking about end up being targeted toward urban areas. The Department of Agriculture provides funding -- a lot of direct funding to rural areas, nonurban areas for affordable housing. So going to the first slide, Department of Agriculture, you can start to see the categories in which the Department of Agriculture funds affordable housing in rural areas. Single-family home programs, these are loans and grants that allow low income families to either rehab their house or build housing. And then the housing (inaudible) grants help with repairs and rehabilitation of existing housing and they are for very, very small towns, towns with less than 20,000 in population. The multifamily housing programs -- in the next slide -- include rural housing, guaranteed rental housing loans and rental assistance. One of the things to know about the multifamily housing rural rental housing loan program is that people with disabilities as specifically mentioned as a possible target tenant group and then the multifamily housing guaranteed rental housing loans, people with disabilities are mentioned specifically as a target group, and the average rent is 30 percent of the median family income, and when we start to talk about strategies for collaboration, you'll see that 30 percent of median family income is something that's very good. Finally, the Department of Agriculture housing programs offer a rental assistance program. It's in conjunction with one of their development 16 programs. We've talked at you a lot about resources that HUD controls, resources controlled by the low income housing tax credit and resources controlled by the Department of Agriculture. And now it's time to hear from you in questions and answers. So are there any questions? >> OPERATOR: At this time if anyone has any questions, press 0 and 1 on your telephone keypad. And our first question will come from Beto. >> CALLER: Hi, we joined in the presentation on public housing. There was quite a bit of information here and it's a lot of opportunities to get more funding from the public housing and in reference to local preferences do we know if any public housing authority in any part in the country have established any type of local preferences other than the usual mainstream vouchers or fair share vouchers? And the other question is, are there any other cities that public housing authorities operate modification funds for participants of the Section 8 program? >> ANN: That's a great question and I really appreciate it. I think that in terms of the local preferences and looking for examples of communities that have established local preferences, I can't tell you that off the top of my head, especially around people with disabilities. I do know that there are communities though that are doing that, and one of the best housing authorities that I know of is the public housing authority in Missoula, Montana, and I don't know off the top of my head if they have established preferences, but I can tell you that they are the best example that I know of of public housing authorities using their ability to invest in the community to integrate affordable housing developments for people 17 who are homeless, including people with disabilities. >> CALLER: I'd be very interested in knowing more about this Montana place, the housing authority. In Chicago, our public housing authority has vouchers to give people in nursing homes and has also a modification fund for people that have Section 8 vouchers. And what about the modification funds, do you know any other organization that might have this type of fund so we can have some type of modification for people that have Section 8 vouchers that want to move into the communities? >> ANN: Well, I think when Sarah was talking about the HOME program, theoretically one of the sources you could use to modify -- you know, to make housing more accessible, to do the modifications, the reasonable modifications, is the HOME program, but it's only for owner occupied housing. So it wouldn't be for multifamily rental property. I'm interested in hearing from you off the call perhaps about the Chicago housing authority and what source of funds they are using for modifications. >> CALLER: Well, when we argue with the Chicago housing authority to create a mod fund, we quoted the 504 -- complying with 504, that individuals with disabilities did not have equal access to the voucher because of the unaccessibility in the community, in the particular low income communities where the vouchers would be taken. As far as where the money comes at the Chicago housing authority, I really -- I'm really not interested in how the public housing authority -- where the money comes from. I just want the money there to be established. I think for us in Chicago, we saw that as their issue. It is the public 18 housing authority issue where the money was going to come from. Our issue was to make it happen. That was about the mod fund. And now also on the vouchers to get people to transition people coming out of nursing homes, I think that's something that local advocates should continue advocating with their local housing authorities as a local preference. >> ANN: Yes, I think that local preference idea is excellent and also some of the other funding sources that we've talked about can be used to help people transition out of nursing homes, specifically rental assistance from the HOME program. So not only can you do rental assistance for access to housing units from the public housing authority, but you can also ask for and receive tenant-based rental assistance from the HOME program. The problem with that is that it's only 24 months of assistance. So you have to transition to something that's longer term, but it will help people get out of the nursing home. >> CALLER: Are you talking about the HOME funds? >> ANN: Yes. >> CALLER: But those are administered at the state level by state finance agencies. >> ANN: They are administered -- >> SARAH: Both at the local level and the state level. That would be a matter of coordinating with your city community development division as well as the other sources used. >> ANN: I can tell you how to find out how much money you get in your community from consolidated plan funds, and what you do is you look up 19 HUD's website, so you go to www.hud.gov. And go to their search engine and type in cpd, that stands for community planning and development. Put it on a search engine and that will lead you to the consolidated planning map and you can click on your state and then your state will show your cities' allocations. Chicago should have a huge allocation of HOME funds. The trick is -- and this leads us into our advocacy section -- that CILs can use. The trick is that many times local and state jurisdictions don't want to use HOME funds for rental assistance. They would rather use it for development. Development is an excellent use, but if you have a need for rental assistance from HOME funds, we should not forget about the HOME funds. >> SARAH: I think we may have time for just one more quick question. Do we have anyone else? >> OPERATOR: At this time, no, there are no further questions in the audio queue. >> SARAH: Okay, great. I think we're ready. >> ANN: Okay. >> SARAH: We're ready to move on to collaboration strategies. >> ANN: As we talked about hopefully by now in the session you have some sense of where the dollars come from. Now we'd like to talk to you about how you can find -- how you can persuade people to work with you around collaborating. And there are two basic arguments that we can make. One is we want you to have the information in housing language. So the first thing we do need to be able to do is talk about people with disabilities as people who are in poverty many times. People that are on 20 SSI or other fixed income, they are frequently falling within the poverty guidelines. The first argument we're going to talk about is approaching perspective housing partners by talking about people with disabilities as a low income group. So -- and then the second thing we're going to talk about, the second argument that can be made or the second persuasive statement that can be made to potential housing partners is helping people with disabilities who have affordable housing needs is the right thing to do. We're going to discuss both of those arguments. Moving to the next slide, making the poverty argument, one of the things we can do is talk about people with disabilities in low income households. As Sarah started to say -- how income levels for households is considered to be moderate income, low income, very low income and extremely low income. And if you look at the slide, you'll see that 80 percent of the median family income in a community is considered low income. >> SARAH: And depending on your community, that can be incredibly high, the median income in Austin, Texas is in the mid 60,000's. So at 80 percent that puts you somewhere maybe 48,000, maybe $50,000 for a household of four. That's quite a bit of income. And so as people who are working with, advocating for and strategizing around income groups, groups of people who make much lower incomes than that, we can say you're not serving those most in need. People who live on fixed incomes, people will have much lower incomes than 80 percent are those that are most in need and that is really how the housing world looks at this. They look at everybody with an income bracket. And they want to make sure that they are serving 21 people across the continuum of housing operations and across a continuum of income. And if we can provide them with strategies to serve people with extremely low incomes, then we're giving them a way to check that box in their consolidated plan and help them serve very low income households. One of the reasons -- and this is kind of an aside, one of the reasons that extremely low income households don't get served is because it's not a (inaudible). They have to do deep subsidies to fewer households than they serve households and as we all know, people who are in politics want to say that they served a lot of households sometimes and that's not necessarily a bad thing, it's just kind of the political reality of if you only have so many dollars to spread around, you'd like to make it go as far as you can. So sometimes those lower income brackets get ignored because they are more difficult and they require more funding to serve. >> ANN: I think that one of the ways from an understanding of low, very low and extremely low income households is that if a household is on the SSI income, they are in the extremely low category. Most of the time jurisdictions do not target funds to that level of income. And so you can ask for targeting -- income targeting without mentioning the disability issue. You could say this consolidated plan needs to serve people who are at the lowest levels of income, and you can ask for extremely low income households to receive a set aside. If we move to the next slide, making the poverty argument continued, is that most HUD programs are set to serve households at 80 percent of median income. There is a disconnect there between what HUD considers low income and what most -- and what the federal government considers to be 22 poverty. And as Sarah was saying, in most communities -- in all communities really the median family income is higher than the poverty level and 80 percent of the median family income, which HUD calls low income, is usually way above the poverty line. Moving to the next slide which is a table, it shows that the -- we just picked at random four communities -- Atlanta, Georgia, Topeka, Kansas, Medford, Oregon and Madison, Wisconsin -- really at random, and if you look, you'll be able to see that in each of those communities, what HUD decides is a low income household for one person is way above the poverty line. And as we all know, an SSI income level household is below the poverty line. So there is a basic disconnect between the way HUD sends money to states and communities and the way that we need to receive it to assist the extremely low income. By HUD's own procedures and their own rules, and this is the next slide, it's possible to make the argument that the housing problems of people with disabilities are more about poverty than they are about disability. There are some specific things that once you have made that point with a potential partner at the state level or at the local level, there are things that could be asked for, things that could be requested that will be helpful. If you move to the next slide and look at some of the successful requests that I've seen is an allocation of 25 percent or more of HOME funds for extremely low income households and dedication of HOME funds to subsidize tax credit properties. One of the reasons that's important, as Sarah said, tax credit developments are not naturally affordable for people 23 with extremely low income. So frequently the way to make tax credit projects affordable is to attach subsidies to them. >> SARAH: Just as you know, I'm sure you are all very creative, there is no need to confine these strategies to the funding programs we talked about today. Sometimes in cities, if you're in a high growth area, cities are doing things all the time and allocating funds to different urban development projects, and I've definitely seen people successfully request that a portion of the housing built for example in a transit oriented design district be set aside for people with low incomes, 60 percent below, 40 percent below, even a portion at 30 percent. So any time you see new funding being allocated towards development projects in your area, that's an opportunity to ask for income targeting to the lowest income bracket. >> ANN: One of the other things that is important to remember about the poverty argument, moving to the next slide, is that if you're talking to funders about people in poverty, then you're going to have a set of allies that you didn't have before. So advocates for the homeless, people focused on addressing poverty, advocates for the elderly and affordable housing organizations in general are going to be your allies because you're making a poverty argument. >> SARAH: And as we all know, the more people that are saying the same thing, the more likely you're going to get a response. So that's why that's such an excellent argument and such a great twist to make because it's a lot harder to ignore by saying that's only a small group. Now you have all of these other groups that would be affected equally by the same income targeting. 24 >> ANN: Right, it's harder for a funding source to say -- to pit groups against each other when you're all making the same argument. This last slide, developing in-house expertise is a list of things that's useful for SILCs to think about. If you have developed a database of housing market conditions for your state, make sure that the CILs in your state know about using set asides and make sure the CILs in your states know about the opportunities to provide input to HUD consolidated plans at both the state and the local level. I think another thing that SILCs can do is provide assistance to CILs in understanding their own housing markets and their own opportunities locally for collaboration. At the state level, it's very important I think for SILCs to be at the table when the housing finance agencies are developing all of these plans, the qualified allocation plan for tax credits, the consolidated plan for HUD funding, their own public housing authority plans, it's very important for SILCs to be part of the group that is having those conversations. >> SARAH: And one note I'd like to make on that is it can be a little bit tricky. Some states divide their housing duties between a housing finance agency and then more of a community development agency. Not always, but in some states you have the housing finance agency controlling tax credits and a community development division controlling things like the HOME funds and so you want to make sure you double-check and are getting both of those organizations at the state level. That's a little bit tricky. The final point we want to make is -- and this goes right along with 25 creating a database on housing market conditions, but if you can develop a fact sheet that talks about the disconnect between the income levels targeted with affordable housing dollars and real poverty, that's very helpful and can be useful at the state level as these plans are being put together. >> ANN: To sum up about the poverty argument, I just want to remind people we're really talking about housing funding organizations in their own language. They talk about incomes of households, they talk about market conditions, and so making the poverty argument allows you to be seen as an objective and dispassionate partner that understands how the world works and makes you look like a better ally. I want to move us now into the other argument for collaboration, and that has to do with making sure -- making it easy for people to do the right thing. That's one of the rules that Sarah and I use in general. You want people to do what's right around allocating resources around people with disabilities. We have a lot of tools from the federal government. We have the Americans with Disabilities Act, the Fair Housing Act, Section 504 of the Rehab Act of 1973 as well as case law. So that's the slide we're on, and moving to the next slide, this is a quick overview of these tools. Section 504 of the Rehab Act prohibits practices that keep people from having equal access to programs. Our questioner from Chicago talked about how that's how they made the argument, they used 504 to make the case of people with disabilities don't have equal access to vouchers without modifications funding. >> SARAH: That's an example of how to take this information and turn 26 it into a strategy for action. As you all know, Section 504 of course applies to any program that receives federal funding. Right? >> ANN: Another tool that I think is excellent is the Fair Housing Act. People with disabilities are considered to be a protected class under the Fair Housing Amendments Act, and if you'll see on the next slide, these are the things that landlords and owners are prohibited from doing. They can't refuse to rent or sell housing, to negotiate, they can't refuse to mange housing available, they can't deny access, they can't set different terms and conditions (inaudible) based on someone's disability. The basic rule is if a group of people is being treated differently because of their difference, then it's a violation of the Fair Housing Act. One of the ways that housing authorities sometimes get around that is by making the rule for everyone. And so if there is a rule or a policy that is applied equally across the board, it is legal usually for people to do that. It's only when groups are treated differently based on their difference. So people with disabilities are treated differently based on their disabilities that it becomes a violation of the law. Moving to the next slide, these are some more provisions of the Fair Housing Act. There is case law -- one of them is everyone on this call I'm assuming is familiar with Olmstead versus L. C. and that is a Supreme Court decision that reinforced that the Americans with Disabilities Act will be enforced in this country and that mandated that people with disabilities live in integrated settings. There is another case of case law called Cason versus The Rochester Housing Authority. And this has to do with -- in the past and in the 27 present now probably people will look at an individual with a disability and say they need to be capable of independent living. And the Cason versus Rochester Housing Authority decision really, really took away the power of that requirement. The courts held the tenant can fulfill the requirements of tenancy in any way they want as long as they can be good tenants, then they don't need to be, quote, capable of independent living or meet a higher standard than any other group to have access to the housing units. >> SARAH: Another example that I can think of is, for example, a landlord or PHA tried to say that people had to have case management to live there. That would be a violation. >> ANN: Another one that's frequently -- for people with physical disabilities, the landlord will look at someone and say you're likely to fall. So if you'll sign the agreement saying you're not going to sue me because you're more likely to fall than anyone else, I'd like you to sign this special agreement that says I won't sue you, that's a violation of federal law. I want to direct your attention to the next slide that says tenants are free to meet the obligations of tenancy without assistance. The next slide tells us that after this decision, HUD changed its rules. Now, those of you on the phone who know HUD know that getting HUD to change their rules is a pretty significant achievement and the fact that they changed their rules so that the ability to live independently is no longer a requirement in their programs is a pretty significant victory. To sum up on the next slide, these pieces of legislation and the 28 related case law really reaffirm that people with disabilities have a right to live in the community, to rent or buy housing on the same terms as anyone else, request reasonable accommodation for disability when needed and have the same rights to housing units as any other tenant. So the same standard lease. We don't have time really to talk about reasonable accommodation, but we could do a whole session on that. >> SARAH: There are two additional slides that sum up on collaboration strategies, one is making the right thing to do argument. I believe Ann really hit these points, but I would just like to emphasize that as part of the planning process, all of the different housing jurisdictions which talked about the local level, the state level, they have to also do an additional document called the analysis of impediments to fair housing. That's a companion really to the consolidated plan. And it outlines what in a local community might be an impediment to fair housing. Now, I have completed a few of these or worked on them, and generally they do get watered down, but it's still a great place for you to go and, one, become aware of what your funding jurisdiction is saying about fair housing; and two, to provide input because it's not that easy to really figure out what the impediments are unless someone is blatantly violating the law, which in this day and age few people are. It's usually more subtle than that. So that's a good thing to know about in particulate the state level. And then our very last slide, once again, some of the best ways to collaborate around the it's the right thing to do argument are very similar to the last points we made which are make sure that you have accurate information about who needs housing, what kind of housing they need, 29 provide input or an analysis of any current discriminatory practices you know about, whether that's, you know, intentional or unintentionally. Generally, it's unintentional. Also review what publicly assisted housing is out there, and you can assess the degree of acceptability and affordability. I definitely know organizations that have gone out and tested different housing, both as official fair housing testers and also just doing drive byes to see if things are accessible, if they are being built accessibly. That's really easy to do with new construction. And then the last thing -- suggestion we make is to publish a report card. And you can give that to your city council, to your state legislature, any public officials you're trying to influence around housing. >> ANN: So to sum up this section on collaboration, we tried to give you information about how to make two arguments that will bring you to your partners, bring you to housing funding agencies as good partners. And one of those is making the poverty argument, which is to talk about households with -- people with disabilities as households in poverty. And to make that poverty argument. The second thing we've talked about is to be experts, the SILCs can be experts on the housing needs of people with disabilities and give the CILs the tools that they need to work for allocations of resources at the local level. We've come all the way up to another question and answer session. Are there questions at this time? >> OPERATOR: Again, at this time you may press 0 and then 1 to ask a question. 30 Our first audio question comes from Victoria. >> CALLER: Yes, I wanted to go back to the local preferences, the request for local preferences specifically targeting people who want to move out of institutions. As I've gone to the various public housing agencies in our area, I've found that some have responded where they feel that it's targeting a specific group, that they may not be permitted to do that under HUD, or they feel that it's redundant because they already have -- well, they already have a local preference for low income working families which also includes people with disabilities. So they feel that adding another local preference that had to do with people with disabilities is somewhat redundant. So how can I respond to that to convince them more so that this is a critical need being prioritized this way would allow people to be more immediately assisted with Section 8 or public housing? >> ANN: Well, actually the public housing authority people who are telling you they can't prioritize one group of people with disabilities over another, that's a correct statement. But you can ask for in local preference for people with disabilities in general. And then within that what you can do is position yourself or help a CIL position themselves in such a way that they are at the front of that line. And what I mean by that is that you have a system in place where you can identify people who want to leave nursing homes, for example, and you have a streamlined process for bringing those individuals to the attention of the housing authority and getting them on the list. One of the reasons that housing authorities don't really like to do 31 preferences is that they have to maintain multiple lists. And that may sound easy to you and me, but there is an administrative burden to having a list for the general households in a community, having a list for people with disabilities, and a list for working families in your example. And so if you're asking them to do another list, another preference, another waiting list, you know, you will have to explain to them how it is to their advantage to do that. I think as Sarah said earlier, part of the thing -- part of the rationale for them is that they look better to HUD because they are serving households at the income levels that they are supposed to serve and they are providing access to housing. They are making special provisions for access to housing for people with disabilities. >> CALLER: Can you hear me? >> ANN: Yes. >> CALLER: I don't feel that turning people who want to transition out of nursing homes is specifically targeting a specific group or population or type of disability. And I know that HUD encourages PHA's to establish such a preference. And you wouldn't actually be establishing a separate list because you would be prioritizing -- assigning a set of points, but I mean how do I respond to those agencies that feel they would be targeting a specific group because they really wouldn't be. >> ANN: I would pull out the regulations, number one, and use HUD's wording and in addition to that, I'm very curious about this working families preference, because that sounds like you're favoring people who have a job and I'm not sure -- I don't think that's illegal, but I just don't like it. Let me put it that way. It seems to rub me the wrong way 32 especially when you're talking about people with disabilities who may work part time or may be unable to go to work in particular for fear of losing benefits and so that may just be some additional education and that also sounds like a place where the income argument can come in. Because if they are working, they're going to have a higher income than somebody who is living on affixed income. So that's definitely an area, if I were in that community, I would want to explore a little bit more what the definition is behind that, what they are really trying to get at. My guess is they may be trying to cleanup some of their projects and they think that by putting the working definition on there, they'll get higher quality tenants. I would definitely explore that a little more and see if you can find out what the motivation is. Maybe there are other funds coming in for people who working. >> CALLER: Low income working families and they have included people with disabilities in that category. So people with disabilities get the same number of points on priority points. My argument is that people with disabilities are competing with those who are low income working families and then also people who want to transition are also competing with other people with disabilities and working families. So to establish separate local preference for people who want to transition, it doesn't seem to me it would create another list. So I'm trying to figure out how I can approach them with even more convincing argument to add that as a local preference. >> ANN: Right. You know, it sounds like -- I'm wondering if there might be a useful conversation we could have off the call where we could 33 help you figure out, you know, based on the local situation. >> SARAH: Yeah, it sounds like some more information about income level is needed, about risk of homelessness, about the cost of keeping people in nursing homes, a bunch of different things could be used. >> ANN: We could help you brainstorm but we ought to move to the next question. >> CALLER: Thank you. >> ANN: Is there a next question? >> OPERATOR: If anyone does have any questions, press 0 and then 1, and our next one comes from a Julian. Go ahead. >> CALLER: Hello. Can you hear me? >> ANN: Yes. >> CALLER: Yes, I think that's a good argument that she wants about the nursing home transition which that I'm facing actually. I don't see why you cannot discuss that now. Is there a way we can discuss that now? >> ANN: Are you asking about a preference for people who work? >> CALLER: No, for transition. >> ANN: We have some ideas about how you can approach that. First of all, we talked about making the poverty argument. I know (inaudible) if you're in a situation where people don't want to do that, it's also possible to have information about how much do nursing homes cost as opposed to rental assistance plus services in regular integrated housing. So I am answering the question. You know, saying that if you want -- making the argument for setting aside funds for nursing home transit's, part of it you make the poverty argument. Part of it you make the argument 34 that it's the right thing to do supported by federal law, supported by case law. The third thing that we did not have slides on, but that we're moving to now is making the economic argument that it is more expensive for people to be in nursing homes than it is to provide them with the rental assistance or housing assistance they need for integrated units in the community. And so part of the answer then becomes you assemble that information for your local community and use that as part of an integrated argument that includes poverty argument, the legal arguments and now an argument about economics. >> CALLER: All right. Thank you. >> ANN: I wasn't trying to stuck the question, I just didn't want us to get stuck on it. >> CALLER: I didn't want to get stuck on it, but at the same time I know that (inaudible). I mean, this is a problem everywhere. >> ANN: No, one of the things we're going to be doing in addition to this call is setting up some topical work groups that meet probably monthly and focus more in depth on these specific issues and specific strategies where we work together with or allies across the country. So stay close for more information about those as well. >> CALLER: Okay. >> SARAH: We absolutely want to help. We want to get into the details of this kind of thing and help SILCs and then help the CILs as well have the information they need to make a difference. >> ANN: I think that's a perfect segue into our last section which is about partnerships. If you go to the slide entitled good partners, we're 35 going to talk about who some of the best partners are and then how you can meet them and things you can do. >> SARAH: Really, I cannot enterprise enough how important it is to get to know people at your state housing finance agency or your state department of housing and community affairs. In Utah, for example, it's called culture and community. So depending on how your state is organized, you may have to do some digging to find out who is running your HOME programs and your consolidated plan and your tax credit programs, but it's extremely important that you find out who that is and begin to get to know those people. Likewise, the people that are serving on your state (inaudible) committee. Any kind of council or organization on homelessness, if you have a regional HUD office or a state HUD office, that's a good ally. >> ANN: Moving to the next slide, one of the things you can do is to meet these people is attend state housing conferences, going to public hearings. >> SARAH: Yeah, you should definitely try to get on any kind of E-mail lists for your state housing network. Ours here in Texas sends out something every couple of weeks and it's just great information about the different forums that they are offering, the different round tables and although some of that may not apply to you, it's just the absolute best way to figure out who the staff is and who else at the state level is participating in these programs and will coming to these. You may have a state organization that serves nonprofit housing developers or a local organization and those are great to get connected with. I refer to those 36 on the slide as trade associations. There are also affordable housing organizations and sometimes those aren't necessarily nonprofits. Sometimes there is a distinction between the nonprofit housing providers and the for profit housing providers that are also providing affordable housing. Definitely go to any state conferences you can. I can remember that early in my career I was invited to go to a housing conference, and doors that opened for me from that housing conference made it possible suddenly for the agency that I was working for to become good partners with the state housing agency. I was educated and I started to know people and so we're suggesting the same thing. These suggestions will bring you into contact with people who are housing experts or housing advocates. Also before we leave this topic as good partners want to talk about once you find potential partners, how can you work with them, and if you move to the next slide, you can -- one of the most formal ways to do that is just to do some sort of formal MOU. So you might end up in a formal partnership or a written relationship with someone where you're going to work together to identify resources to create a plan for allocating resources that would support people with disabilities in regular integrated housing. And a standard MOU, put forth your mutual goals and decide what each party is going to do and set a time line and then move forward. An easier thing to do maybe is to offer cross training. With a housing agency, you might not invite a housing agency to a SILC meeting to talk with did resources the housing agency controls, talk about eligibility, talk about how they work with partners in general, and then 37 you might reciprocate by providing training to them on the poverty argument and the housing needs of people with disabilities. So you can share information. >> SARAH: That's really an excellent way just to get to know each other, you know, to have them come to a meeting that you're having or if you have a disability policy consortium, any kind of state level group that's meeting around the different challenges faced by people with disabilities, if you just invite someone from the housing world to come, it is a great way for them to suddenly realize that there is a whole other group of people out there that may need housing assistance and that may be potential partners for them. I think that's really a great first step if you're not already familiar with who is doing what in your state. >> ANN: Again, some of the content for that cross training is stuff we've already talked about. You give them information about how the housing needs of people with disabilities are more about poverty than they are about disability. And then you give them information about housing markets and you give them information about how they can serve households in poverty. That's one set of information to give them. The other set of information to give them is a real picture of your potential tenant group. You can also do that with a trade association. For example, have someone come if you have an affiliation of affordable housing providers, have them come and talk about what they do and then you're able to provide information on this entire group of tenants, potential tenants for them, and talk about partnerships and I have definitely seen some very successful partnerships around the country linking developers and then groups that 38 have contact with people with disabilities in order to get a unit set aside for persons with disabilities within a larger housing complex. So there is a lot of good examples of that out there. >> ANN: And so we are happy to go on and on talking about examples we can do that, but I wanted to pause again and leave room for the final question and answer session. Are there any questions? >> OPERATOR: Thank you, and at this time if you do have any questions, press 0 and then 1 on your telephone keypad. It appears at this time there are inform questions in the audio queue. Tim, do we have any questions through the web? >> TIM: We do, thank you, Matt. I'm going to jump back a little bit here. We've used all the time in the Q. and A. sessions, I have a bit of a back log. So jumping back to HUD and Section 8 specifically, mark Miller from Long Island and excuse me I'm going to paraphrase here. This comments that Long Island has now been one of the ten most expensive places in the country to live. And he asks specifically about landlords not being required by law to accept Section 8 vouchers. And specifically in areas such as Long Island where with rents and home prices so high, that folks with Section 8 vouchers are quickly passed over. Mark just asked if you have any tips forgetting around that? >> SARAH: I think this is where building partnerships and doing good P. R. really comes in. A lot of times if you can help provide a steady stream of tenants or show that tenants would disabilities are more stable, they have a lower turn over rate, which a lot of times people say once they make their apartment accessible for them, they don't want to move. So 39 doing some things to talk about the population you'd like to see them serve, getting them facts as Ann mentioned earlier, and then it really is a P. R. campaign. Now, in today's market with things -- even though prices are still very high, it's hard to find a rental unit at all in some areas and so you may have some additional challenges that way, but you also -- if the people's income are unsure and you can get a voucher from someone, then that's a steady income. So that's another way to spin this as a steady stream of income, a solid tenant, solid income, someone who is not going to turn over. >> ANN: The only thing I would add to that is to say that landlords are required to accept Section 8 if the housing was built with certain kinds of federal funding. >> SARAH: Yes, so you want to be on top of which different apartment units in your area have federal funds there and is a variety of ways to find out. You probably start with the HUD website and then also your state housing finance agency to find out which apartments have subsidies. >> ANN: Next question. >> TIM: Okay, I'll go ahead with another one from the webcast here. I have a question that asks about the analysis of the fair housing -- I'm assuming they are talking about the Fair Housing Act and whether or not that is a requirement of HUD and more specifically how that relates to the consolidated plan? >> SARAH: I think they probably mean the analysis of impediments to fair housing, and yes, it is a requirement that each jurisdiction, whether that's the state or the local area, complete an analysis of impediments to 40 fair housing. The specific requirements of what needs to be in an AI as these are referred to sometimes is on the HUD website and it includes specific guidelines that need to be addressed. They are done every five years and have to be updated every five years and I believe they have some sort of action plan within them as well, but it's been a little while since I looked at them. Ann, do you have anything to add? But it's another thing -- your local jurisdiction and your state level, just call them up and ask where you find your analysis of impediments on fair housing and it may take you a while to find somebody who knows, but I would definitely start with whoever is doing your consolidated plan. >> ANN: Next question or follow up? >> TIM: That's my final question then. Mark from Florida asks if the local preference could be set to, in quotes, overcome discrimination, and then to make the argument to the PHA's -- the housing authority to set a preference for people with disabilities? >> ANN: Well, now there is -- if you look at the Bazelon Center for Mental Health Laws, you'll see that there is an argument to be made that if standard practices have a discriminatory sect, that the PHA or whoever your target is, must make changes to their standard practices in order to allow equal access to programs and facilities. And so it might be -- that might be an argument. I would do a more traditional approach first which is to say that -- you know, just outline what the costs are associated with not housing people with disabilities, which could be homelessness or nursing home care which is a lot more expensive. 41 >> SARAH: Yeah, and just to follow up on that, really we haven't talked about other allies, but really the state department that deals with mental health, those are possible allies for you in making this argument that housing people in the community is less expensive and a better use of resources than nursing homes or other institutions. >> ANN: And sometimes they have some discretionary funding that they can provide help with getting people set up to move, deposits or electricity or you I will its, other things like that. >> TIM: Great. That's all the questions I have from webcast participants. Matt, are there any other questions from our audio participants? >> OPERATOR: Again, if we do have any other questions from the audio, please press 0 and then 1. And we do. We have one question coming from an Elaine. Go ahead, Elaine. >> CALLER: Hello. >> OPERATOR: Yes, go ahead, Elaine. Your line is open. >> SARAH: Elaine, we can't hear you. >> CALLER: Discretionary money. >> OPERATOR: Go ahead. >> CALLER: Hello. Hi, this is Laurie from St. Joseph. The question I had was just mentioned, who has the discretionary funds for people to move -- >> SARAH: Sure, I was just saying that sometimes the state divisions of health or divisions of mental health will have pots of money that they can use for those types of things. There is not a specific fund, it's 42 going to vary state by state, and the funding that they have will vary state by state, but I have seen at that level organizations use funds in a way to help people move from institutions or nursing homes. Typically they'll start off with a pilot program. >> ANN: If you want a specific example, the state of Texas offers a 2,400-dollars in relocation assistance to people month are exiting nursing homes. >> CALLER: Okay, thank you. >> OPERATOR: Thank you. At this time there are no further audio questions. >> TIM: We have a few minutes left and I've gotten one more question in from the webcast. I'll pass this a long. It comes from sandy. Sandy relays that they have a PHA that is not yet certified by HUD and they are not interested in giving any preference to individuals with disabilities and sandy asks if y'all have any suggestions on how to work with them and how to encourage them to become certified. >> ANN: You know, I'm actually sort of baffled. Are they receiving -- I know you can't ask this, but are they receiving funds from HUD as a public housing authority without that certification, or are they an organization seeking certification? Are they getting money or not? >> TIM: The only clue is not yet certified and I so, sandy f you want to answer that, you're welcome to E-mail me and follow up. >> SARAH: I was just going to say I assume that once they became certified they'd be eligible for more money. That's one way to encourage them. And then in terms of, you know, if they are not at all interested in 43 serving people with disabilities, typically, you know, I would just suggest to become the squeaky wheel. Keep after it, and I have seen that work so well. I've seen so much positive change just even in our local community, but in communities throughout Texas where people just kept showing up for the meetings and weren't going to go away, and when they needed to get feisty, they did, and when they needed to back off and just use data and information, they did that as well. And over time they became an element that could not be ignored. >> ANN: You know, the key to doing that effectively is knowing your own argument and your own market. So having all the information about why the public housing authority needs to serve this population in a special way because the common practices are not providing equal access to the programs. All of those arguments, if you put that together and then you use it over and over again -- so working with what Sarah said, be the squeaky wheel, never pass up an opportunity for public comment, you know, always know your stuff, know your information, don't make mistakes in terms of what you're saying about the housing market, but never let them off the hook. The other thing I would say is public housing authorities -- while you're doing that, there are other potential allies out there. If this PHA will not work with you, keep after them because they control resources. So you could also look for other allies and make look at tax credits, maybe you want to look at consolidated plan funding, maybe you want to look at the Department of Agriculture, the housing trust fund at the state level, look for other opportunities as well. 44 >> TIM: All right. Thanks. Well, that brings us to 4:29:00 p.m., and I want to thank Ann and Sarah for an excellent presentation for all of you for good questions and for being on today's call. I don't have much to do to end the call here except I want to relay again the website where you can access of course the materials which hopefully you've already gotten, but most importantly the evaluation form for today's call and that website again is www.ncil.org/training/accessiblehousingmaterials.HTML. The other thing I want to do today is just provide myself as a liaison to Ann and Sarah if you all have any follow-up questions. In today's presentation, they made it clear they would remain available after the call if there were any questions or as we indicated through the topical work groups or to help any of you work on some more spesk problems that you're experiencing in your communities. So I want to thank them for making that offer and the simplest way to do that I think is probably just to pass your questions a along to me at tim@ncil.org. And if I can't answer the question myself, then I'll be happy to pass it along to Ann and Sarah. I also want to thank everyone at ILRU, at APRIL and NCIL, especially Rob Dickehuth and Marie Bryant for making today's webcast possible and at 4:31 p.m. I need to stop there. So please contact me if we can do anything further. Don't forget to fill out your evaluation forms and thanks so much to everyone. Bye-bye.