Louisville Metro Housing Authority (LMHA) Housing Choice Voucher (HCV) Program Administrative Plan For Public Comment: December 8, 2016 – January 10, 2017 LOUISVILLE METRO HOUSING AUTHORITY (LMHA) HOUSING CHOICE VOUCHER (HCV) PROGRAM ADMINISTRATIVE PLAN The LMHA is proposing changes to the following sections: Section 3: Section 4: Section 5: Section 6: Section 10: Section 11: Glossary Appendix 1: Appendix 9: Eligibility for and Denial of Assistance The Admissions Process Determining Annual Income Leasing a Unit Verification Rent and Housing Assistance Payment Payment Standards (Including Maps) Special Referral Programs Public comment welcome from December 8, 2016 – January 10, 2017 1 Louisville Metro Housing Authority (LMHA) Housing Choice Voucher (HCV) Program Administrative Plan For Public Comment: December 8, 2016 – January 10, 2017 3. ELIGIBILITY FOR AND DENIAL OF ASSISTANCE A. ELIGIBILITY CRITERIA […] 4. Social Security Number Disclosure Eligibility Criteria1 a. Applicant Family Disclosure of Social Security Numbers i. Required Disclosure Prior to Admission of Applicant Family Prior to admission, every Household Member regardless of age must provide LMHA with a complete and accurate Social Security Number with the exception of Household Members who meet the criteria for any one of the exceptions described in section 3.A.4.a.ii of this Administrative Plan. If any Household Member has not yet disclosed his or her Social Security Number at the time the Family reaches the top of the waiting list, the LMHA will request in writing that the Household Member(s) disclose and document their Social Security Number within 30 calendar days. The Family will maintain their position on the waiting during this period of time. However, if all Household Members have not disclosed and documented their Social Security Number at the time a Housing Choice Voucher becomes available, the Housing Authority will offer the Voucher to the next eligible Applicant Family on the waiting list. If the Family fails to disclose and document the Household Member’s Social Security Number within 30 calendar days, the Family will be removed from the waiting list. ii. Exceptions to Required Disclosure Prior to Admission Household Members who meet any one of the following exceptions can be admitted to the HCV Program without prior disclosure and/or verification of a Social Security Number: 1 24 CFR 5.216, “Disclosure and Verification of Social Security and Employer Identification Numbers”; 24 CFR 5.218, “Penalties for Failing to Disclose and Verify Social Security and Employer Identification Numbers”; PIH 2012-10, Verification of Social Security Numbers (SSNs), Social Security (SS) and Supplemental Security Income (SSI) Benefits; and Effective Use of the Enterprise Income Verification (EIV) System’s Identity Verification Report; PIH 2016-05, Streamlining Administrative Regulations for Programs Administered by Public Housing Agencies For additional information regarding the verification of Social Security Numbers, see Section 10.4. 2 Louisville Metro Housing Authority (LMHA) Housing Choice Voucher (HCV) Program Administrative Plan For Public Comment: December 8, 2016 – January 10, 2017 (A) Household Members Who Do Not Contend Eligible Immigration Status No post-admission verification of Social Security Number is required. (B) Household Members Under the Age of Six Who Were Added to the Applicant’s Household Within the Six-Month Period Prior to the Effective Date of the Housing Assistance Payment Contract Applicant Families that include such a Household Member(s) will be given 90 calendar days from the effective date of the Housing Assistance Payment contract to provide documentation of a complete and accurate Social Security Number. LMHA will grant one additional 90-day grace if the Housing Authority determines that the Family’s failure to comply with the Social Security Number documentation requirement was due to unforeseen circumstances and outside the control of the Family. If upon the expiration of the provided time period, the Family fails to comply with the Social Security Number disclosure and documentation requirements, LMHA will terminate the Family’s assistance. (C) Homeless Applicants to the Housing Authority’s YMCA or St. Vincent DePaul Single Room Occupancy Programs2 Such Applicants may be admitted to the HCV Program without disclosing a Social Security Number. However, the individual must provide LMHA with such documentation within 90 calendar days from the date of admission. The Housing Authority may grant the individual one 90-day extension, if the LMHA determines that the individual’s failure to comply with the Social Security Number documentation requirement was due to unforeseen circumstances and outside the control of the Family. If upon the expiration of the provided time period, the individual fails to comply with the Social Security Number disclosure and documentation requirements, the LMHA will terminate the individual’s assistance. 2 See Appendix 8 for more information about these programs. 3 Louisville Metro Housing Authority (LMHA) Housing Choice Voucher (HCV) Program Administrative Plan For Public Comment: December 8, 2016 – January 10, 2017 4. THE ADMISSIONS PROCESS […] E. NON-WAITING LIST ADMISSIONS 1. Special Admissions When Assistance Is Targeted by HUD3 Occasionally, the LMHA receives HCV (Section 8) funding from HUD that is targeted for Families living in specified units. In these cases, the LMHA must use the assistance for Families living in these units. If necessary to meet the HUD requirements associated with this funding, the LMHA may admit Applicant Families that are not on the Housing Authority’s waiting list or admit Applicant Families without considering their waiting list position. The following are examples of types of program funding that may be targeted for a Family living in a specified unit: a. A Family displaced because of demolition or disposition of a public housing project; b. A Family residing in a multifamily rental housing project when HUD sells, forecloses or demolishes the project; c. For housing covered by the Low Income Housing Preservation and Resident Homeownership Act of 1990 (41 U.S.C. 4101 et seq.): i. A non-purchasing Family residing in a project subject to a homeownership program (under 24 CFR 248.173); or ii. A Family displaced because of mortgage prepayment or voluntary termination of a mortgage insurance contract (as provided in 24 CFR 248.165); d. A Family residing in a project covered by a project-based Section 8 HAP contract at or near the end of the HAP contract term; and e. A non-purchasing Family residing in a HOPE 1 or HOPE 2 project. […] 3 24 CFR 982.203, “Special Admissions (Non-Waiting List): Assistance Targeted by HUD” 4 Louisville Metro Housing Authority (LMHA) Housing Choice Voucher (HCV) Program Administrative Plan For Public Comment: December 8, 2016 – January 10, 2017 5. DETERMINING ANNUAL INCOME […] C. ITEMS EXCLUDED FROM ANNUAL INCOME […] 47. The first $7,500 of earned income received by an Elderly Family whose only other sources of income (in addition to earnings from employment) are Social Security entitlements.4 […] 6. LEASING A UNIT A. DETERMINING THE SUBSIDY STANDARD5 The Louisville Metro Housing Authority (LMHA) will issue a Housing Choice Voucher (HCV) for a particular bedroom size; the bedroom size is a factor in determining the Family’s level of assistance. The following guidelines will determine the Family Unit Size without overcrowding or over-housing: Number of Bedrooms 0 1 2 3 4 5 Number of Persons Minimum Maximum 1 1 1 2 2 4 3 6 4 8 5 10 These standards are based on the assumption that each bedroom will accommodate no more than two persons. In determining bedroom size, the LMHA will include: 4 5 MTW Activity #6-2008, “Earned Income Disregard for Elderly Families” 24 CFR 982.401(d)(2)(ii), “Housing Quality Standards (HQS): Space and Security: Acceptability Criteria”; 24 CFR 982.402, “Subsidy Standards” 5 Louisville Metro Housing Authority (LMHA) Housing Choice Voucher (HCV) Program Administrative Plan For Public Comment: December 8, 2016 – January 10, 2017 1. Children currently under a 50% or more joint custody decree or children for whom a Household Member is listed as the primary residential parent on a joint custody decree; and 2. Children who are temporarily in foster care. A Family that consists of a pregnant woman (and no other persons) will be treated as a twoperson Family. Sleeping arrangements within the unit are determined by the Family. The following guidelines will be used solely to establish the number of bedrooms for which the Family is eligible to receive subsidy: 1. In general, each two Household Members are eligible for no more than the subsidy provided for one bedroom increment; 2. Each two Adults Household Members are eligible for no more than the subsidy provided for one bedroom increment unless they share one of the following relationships: parent/child, grandparent/grandchild, or siblings of the opposite sex; 3. Each two children Minors of the same sex, regardless of age, are eligible for no more than one bedroom increment; 4. children Minors of the opposite sex are eligible for separate bedrooms increments; 5. Foster Children and Foster Adults will be treated in the same manner as Family Members; 6. No more than one person may live in a zero-bedroom unit; and 7. Each Live-In Aide is eligible for one, separate bedroom increment. LMHA does not provide additional bedrooms increments for members of the Live-In Aide’s family. The LMHA will grant an exception to normal Subsidy Standards by providing a Housing Choice Voucher for a larger Family Unit Size only as a Reasonable Accommodation for a Household Member with a disability (See Section 2.B of this Plan for more information about Reasonable Accommodation.). The Family Unit Size will be determined by the LMHA in accordance with the above guidelines, and the Family Unit Size will determine the maximum rent subsidy for the Family. However, the Family may select a unit that is larger or smaller than the Family Unit Size, provided there is at least one bedroom for each two persons. If the Family selects a smaller unit, the Payment Standard for the smaller size will be used to calculate the subsidy. 6 Louisville Metro Housing Authority (LMHA) Housing Choice Voucher (HCV) Program Administrative Plan For Public Comment: December 8, 2016 – January 10, 2017 If the Family selects a larger size, the Payment Standard for the Family Unit Size will determine the maximum subsidy. […] 10.0 VERIFICATION […] 10.4 VERIFICATION OF SOCIAL SECURITY NUMBERS Prior to admission, each Household Member who does not fall into one of the exception categories listed in section 3.A.4.a.ii of this Administrative Plan Family Member who has a Social Security Number and who is at least six years of age must provide verification of his or her Social Security Number by providing one of the following: A. A valid Social Security Number card issued by the Social Security Administration; B. An original document issued by a federal or state government agency, which contains the name of the individual and the Social Security Number of the individual, along with other identifying information of the individual; or C. Such other evidence of the Social Security Number as HUD may prescribe in administrative instructions. Social Security Numbers for Participants will be verified at the following times: A. Social Security Numbers Not Previously Disclosed If a person is already a Household Member and has not disclosed and documented his or her Social Security Number, it must be disclosed and verified at the next Regularly-Scheduled or Interim Re-Examination. B. Assignment of a New Social Security Number If a Household Member has been assigned a new Social Security Number, it must be disclosed and verified at the next Regularly-Scheduled or Interim ReExamination. C. Elderly Household Members Household Members age 62 or older as of January 31, 2010, whose initial eligibility determination was begun before January 31, 2010, are exempt from the required disclosure and verification of their Social Security Number. This exemption continues even if the individual moves to a new assisted unit. 7 Louisville Metro Housing Authority (LMHA) Housing Choice Voucher (HCV) Program Administrative Plan For Public Comment: December 8, 2016 – January 10, 2017 D. New Household Members Age Six or Older Social Security Numbers for new Household Members age six or older must disclosed and verified before the new Member can be added to the Household. E. New Household Members Under the Age of Six If the new Household Member is under the age of six and has not been assigned a Social Security Number, the Family will have 90 calendar days after the child is added to the Household to disclose and verify a complete and accurate Social Security Number. The Housing Authority will grant one 90-day extension for newly added Household Members under the age of 6 if in its sole discretion it determines that the Family’s failure to comply was due to circumstances that could not have reasonably been foreseen and was outside the control of the Family. The best verification of the Social Security Number is the original Social Security card. If the card is not available, LMHA will accept a letter from Social Security that establishes and states the number. Documentation from other governmental agencies will also be accepted that establish and state the number. Driver's license, military ID, passports, or other official documents that establish and state the number are also acceptable. If individuals state that they do not have a Social Security Number they will be required to sign a statement to this effect. An adult must sign for minor children. The Louisville Metro Housing Authority will not require any individual who does not have a Social Security Number to obtain a Social Security Number. If a member of an applicant family indicates they have a Social Security Number, but cannot readily verify it, the family cannot be assisted until verification is provided. If a member of a participating family indicates they have a Social Security Number, but cannot readily verify it, they shall be asked to certify to this fact and shall up to 60 calendar days to provide the verification. If the individual is at least 62 years of age, they will be given 120 calendar days to provide the verification. If the individual fails to provide the verification within the time allowed, the family will be denied assistance or will have their assistance terminated. […] 10.6 FREQUENCY OF OBTAINING VERIFICATION […] For each Household Member who does not contend eligible immigration status age 6 and above, verification of his or her Social Security Number will be obtained only once in accordance with the policies described in sections 3.A.4 and 10.4 of this Administrative Plan. This verification will be accomplished prior to admission. When a family member 8 Louisville Metro Housing Authority (LMHA) Housing Choice Voucher (HCV) Program Administrative Plan For Public Comment: December 8, 2016 – January 10, 2017 who did not have a Social Security Number at admission receives a Social Security Number, that number will be verified at the next regular reexamination. Likewise, when a child turns six, their verification will be obtained at the next regular reexamination. 11.0 RENT AND HOUSING ASSISTANCE PAYMENT […] 11.4 MAXIMUM SUBSIDYTHE PAYMENT STANDARD The Payment Standard adopted by LMHA or one over 110% of the Fair Market Rent that has been approved by HUD determines the maximum subsidy for a family. For the Housing Choice Voucher Program, the minimum payment standard will be 90% of the FMR and the maximum payment standard will be 110% of the FMR without prior approval from HUD, or the exception payment standard approved by HUD. 11.4.1 Setting the Payment Standard By statute, LMHA may set the Payment Standard to any value between 90% and 110% of the Fair Market Rent without HUD's prior approval. The Housing Authority will review its determination of the Payment Standard annually after HUD publication of new Fair Market Rents. LMHA will consider vacancy rates and rents in the market area, size and quality of units leased under the HCV Program, rents for units leased under the HCV Program, success rates of Housing Choice Voucher holders in finding units, and the percentage of Annual Income Families are paying for rent under the HCV Program. If the Housing Authority determines that success rates will suffer or that Families will have to rent low quality units located in poverty-impacted neighborhoods or pay over 40% of Annual Income for rent, the Payment Standard may be raised to the level judged necessary to alleviate these hardships. The objective is to allow Families a reasonable selection of modest, decent, and safe housing in a range of neighborhoods. LMHA may establish a higher Payment Standard of not more than 120% of the published Fair Market Rent (although still within 110% of the published fair market rent) as a Reasonable Accommodation for a Family that includes a person with disabilities. With approval of the HUD Field Office, the payment standard can go to 120%. Any increased Payment Standard approved as a Reasonable Accommodation must still meet the Reasonable Rent requirements described in sections 11.2 and 11.3 of this Administrative 9 Louisville Metro Housing Authority (LMHA) Housing Choice Voucher (HCV) Program Administrative Plan For Public Comment: December 8, 2016 – January 10, 2017 Plan.6 See section 2.B for additional information about the Reasonable Accommodation process. For an HCV tenancy in an insured or noninsured 236 project, a 515 project of the Rural Development Administration, or a Section 221(d)(3) below market interest rate project the maximum subsidy may not exceed the basic rent charged including the cost of tenantpaid utilities. For manufactured home space rental, the maximum subsidy under any form of assistance is the Fair Market Rent for the space as outlined in 24 CFR 982.888. […] 11.6 UTILITY ALLOWANCE […] LMHA uses the appropriate Utility Allowance for the lesser of the size of the dwelling unit actually leased by the Family or (rather than the Family unit size as determined under the Housing Authority subsidy standards). In cases where the unit size leased exceeds the Family unit size as determined under the Housing Authority’s subsidy standards as a result of a Reasonable Accommodation, LMHA will use the appropriate Utility Allowance for the size of the dwelling unit actually leased by the Family.7 […] GLOSSARY Affiliated Individual. With respect to an individual means: A. A spouse, parent, brother, sister, or child of that individual, or an individual a person to whom that individual stands in loco parentis, in the place of a parent or guardian (for example, the affiliated individual is a person in the care, custody, or control of that individual); or B. Any individual, Tenant, or lawful occupant living in the Household of that individual. (78 FR 47717 24 CFR 5.2003) Bifurcate. With respect to a public housing or a Section 8 [HCV Program] Lease, To divide a Lease as a matter of law, subject to the permissibility of such process under the requirements of 24 CFR 982.503, “Payment Standard Amount and Schedule”; 24 CFR 982.505, “How to Calculate Housing Assistance Payment” 7 24 CFR 982.517, “Utility Allowance Schedule” 6 10 Louisville Metro Housing Authority (LMHA) Housing Choice Voucher (HCV) Program Administrative Plan For Public Comment: December 8, 2016 – January 10, 2017 the applicable HUD-covered program and state or local law, such that certain Tenants or lawful occupants can be evicted or removed and the remaining Tenants or lawful occupants can continue to reside in the unit under the same Lease requirements or as may be revised depending upon the eligibility for continued occupancy of the remaining Tenants and lawful occupants. while the remaining Family Members' Lease and occupancy rights are allowed to remain intact. (24 CFR 5.2003) Chronically Homeless. A. A “homeless individual with a disability,” as defined in section 401(9) of the McKinney Vento Homeless Assistance Act (42 U.S.C. 11360(9)), who: 1. Lives in a place not meant for human habitation, a safe haven, or in an emergency shelter; and 2. Has been homeless and living as described in paragraph A.1 of this definition continuously for at least 12 months or on at least 4 separate occasions in the last 3 years, as long as the combined occasions equal at least 12 months and each break in homelessness separating the occasions included at least 7 consecutive nights of not living as described in paragraph A.1. Stays in institutional care facilities for fewer than 90 days will not constitute as a break in homelessness, but rather such stays are included in the 12-month total, as long as the individual was living or residing in a place not meant for human habitation, a safe haven, or an emergency shelter immediately before entering the institutional care facility; B. An individual who has been residing in an institutional care facility, including a jail, substance abuse or mental health treatment facility, hospital, or other similar facility, for fewer than 90 days and met all of the criteria in paragraph A of this definition, before entering that facility; or C. A Family with an Adult Head of Household (or if there is no Adult in the Family, a Minor Head of Household) who meets all of the criteria in paragraph A or B of this definition, including a Family whose composition has fluctuated while the Head of Household has been homeless. (24 CFR 578.3) Domestic Violence. Includes felony or misdemeanor crimes of violence committed by a current or former Spouse or Intimate Partner of the Victim, by a person with whom the victim shares a child in common, by a person who is cohabitating with or has cohabitated with the victim as a Spouse or Intimate Partner, by a person similarly situated to a spouse of the victim under the domestic or family violence laws of the jurisdiction receiving grant monies, or by any other person against an Adult or youth victim who is protected from that person's acts under the domestic or family violence laws of the jurisdiction. (24 CFR 5.2003) Extremely Low-Income Family. A Very Low-Income Family whose Annual Income does not exceed the higher of: A. the federal poverty level guidelines established by the Department of Health and Human Services applicable to the Family of the size involved (except in the case of Families living in Puerto Rico or any other territory or possession of the United States); or B. 30% of the median income for the area, as determined by HUD, with adjustments for smaller and larger families, except that HUD may establish income ceilings higher or lower 11 Louisville Metro Housing Authority (LMHA) Housing Choice Voucher (HCV) Program Administrative Plan For Public Comment: December 8, 2016 – January 10, 2017 than 30% of the area median income for the area if HUD finds that such variations are necessary because of unusually high or low Family incomes. (24 CFR 5.603) Extremely low-income limits can be found at: http://www.huduser.org/portal/datasets/il.html Gender Identity. The gender with which a person identifies, regardless of the sex assigned to that person at birth and regardless of the person's perceived gender identity. Perceived gender identity means the gender with which a person is perceived to identify based on that person's appearance, behavior, expression, other gender related characteristics, or sex assigned to the individual at birth or identified in documents. Actual or perceived gender-related characteristics. (24 CFR 5.100) Medical Expenses. Medical expenses, including medical insurance premiums, that are anticipated during the period for which Annual Income is computed, and that are not covered by insurance. (24 CFR 5.603) LMHA uses Internal Revenue Service (IRS) Publication 502, Medical and Dental Expenses, as the standard for defining what else qualifies as a medical expense. See https://www.irs.gov/pub/irs-pdf/p502.pdf Sexual Orientation. One’s emotional or physical attraction to the same and/or opposite sex (e.g., homosexuality, heterosexuality, or bisexuality.) (24 CFR 5.100) Spouse or Intimate Partner of the Victim. A person who is or has been in a social relationship of a romantic or intimate nature with the victim, as determined by the length of the relationship, the type of the relationship, and the frequency of interaction between the persons involved in the relationship. (24 CFR 5.2003) Stalking. Engaging in a course of conduct directed at a specific person that would cause a reasonable person to: A. Fear for the person’s individual safety or the safety of others; or B. Suffer substantial emotional distress. A. 1. To follow, pursue, or repeatedly commit acts with the intent to kill, injure, harass, or intimidate another person; or 2. To place under surveillance with the intent to kill, injure, harass, or intimidate another person; and B. In the course of, or as a result of, such following, pursuit, surveillance, or repeatedly committed acts, to place a person in reasonable fear of the death of, or serious bodily injury to, or to cause substantial emotional harm to 1. That person; 2. An Immediate Family Member of that person; or 3. The spouse or intimate partner of that person. (24 CFR 5.2003) 12 Louisville Metro Housing Authority (LMHA) Housing Choice Voucher (HCV) Program Administrative Plan For Public Comment: December 8, 2016 – January 10, 2017 13 Louisville Metro Housing Authority (LMHA) Housing Choice Voucher (HCV) Program Administrative Plan For Public Comment: December 8, 2016 – January 10, 2017 APPENDIX 1: PAYMENT STANDARDS (INCLUDING MAPS) [Insert the following table] […] 14 Louisville Metro Housing Authority (LMHA) Housing Choice Voucher (HCV) Program Administrative Plan For Public Comment: December 8, 2016 – January 10, 2017 APPENDIX 9: SPECIAL REFERRAL PROGRAMS […] Louisville Metro Housing Authority Special Referral Programs Social Service Partner Center for Accessible Living (Mainstream Program) Center for Women & Families Population Served Families where head-ofhousehold or spouse is disabled Address 305 W. Broadway, Suite 200, 40202 Contact Information Phone8 Web Voice: www.calky.org/ 589-6620 services/housin TTY: g 589-6690 Vouchers Available 300 Victims of domestic or sexual violence 927 S. 2nd St., 40206 581-7200 Choices Homeless Families 419 S. Shelby St, 40202 585-3780 ChooseWell Communities Pregnant or post-partum mothers who have completed addiction treatment 323 W. Broadway, #504, 40202 800-5204914 Coalition for the Homeless Homeless Families with school-age child(ren) 1300 S. 4th St., #250, 40208 636-9550 http://louhomel ess.org 20 Coalition for the Homeless Chronically homeless Families transitioning from temporary homeless services vouchers 1300 S. 4th St., #250, 40208 636-9550 http://louhomel ess.org 100 (Pending HUD Approval) Day Spring Adults with developmental disabilities 3430 Day Spring Court, 40213 636-5990 http://dayspring ky.org 4 Family Scholar House One parent Families where parent has high school diploma or GED & wishes to pursue college degree 403 Reg Smith Circle, 40208 584-8090 www.familysch olarhouse.org 220284 Kentucky Cabinet for Health & Family Services (Partnership for Families) Families where housing is the only remaining issue preventing reunification of child(ren) with parents or child(ren) being removed from household Kentucky Cabinet for Health & Family Services / Families where at least one Family Member has a severe psychiatric illness 8 CHFS DCBS Jefferson Regional Office 908 W. Broadway, 4 East, 40203 CHFS DCBS Jefferson Regional Area code is 502 unless otherwise noted. 15 www.thecentero nline.org www.choicesho me.org www.choosewell.org/whatwe-do/projectthrive/ 22 5 70 595-4732 70 595-4732 10 Louisville Metro Housing Authority (LMHA) Housing Choice Voucher (HCV) Program Administrative Plan For Public Comment: December 8, 2016 – January 10, 2017 Kentucky Housing Corporation Kentucky Department for Behavioral Health Louisville Substance Abuse & Mental Health Administration Community Consortium (100,000 Homes Initiative) Individuals with severe & persistent psychiatric illness Office 908 W. Broadway, 4 East, 40203 100 Fair Oaks Ln., 4EB, Frankfort, KY, 40621 564-4527 http://dbhdid.ky .gov 5060 568-6972 http://www.fhcl ouisville.org/he althservices/healthc are-for-thehomeless 130 http://www.fhcl ouisville.org/he althservices/healthc are-for-thehomeless 10 Chronically Homeless Families 712 E. Muhammad Ali Blvd, 40202 Phoenix Health Center Families leaving HUD’s Shelter + Care Program 712 E. Muhammad Ali Blvd, 40202 568-6972 Seven Counties Services Centerstone People with Severe Mental Illness 101 W. Muhammad Ali Blvd, 40202 589-1100 Wellspring Individuals with severe & persistent psychiatric illness or intellectual disabilities PO Box 1927, 40201 753-1456 16 www.sevencou nties.org www.wellsprin g-house.org 50 23
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