Portal Policy

Northwest Georgia Housing Authority
Digital Services, Online Payments, & Tenant Portal Access Policy

1. Purpose and Scope 
   NWGHA establishes this policy to standardize and promote the responsible use of digital services while ensuring equitable access for all residents. The policy designates RentCafe as the primary platform for online rent payments, the tenant portal as the primary platform for routine resident communications and document submission, and sets standards for online recertification and other digital interactions.
   
   This policy is intended to improve administrative efficiency, reduce processing times, enhance resident convenience, and support modern housing management practices, without creating technological barriers or penalizing residents who face obstacles to digital participation or who choose not to participate digitally.
   
   Scope. This policy applies to all NWGHA public housing residents, households, and applicants (as applicable). It supplements and shall be read in conjunction with the NWGHA dwelling lease, the Admissions and Continued Occupancy Policy ("ACOP"), applicable HUD regulations, and the NWGHA Grievance Procedure. In the event of any conflict with governing law, HUD regulations, the lease, or the ACOP, the higher legal authority shall control. This policy governs the method of submission, payment, and communication; it does not modify substantive obligations or rights established by governing law, the lease, or the ACOP.
   
   
2. Definitions
   
   
   • Approved Exception means a written or documented determination by NWGHA recognizing that use of a particular digital service or payment method is not feasible for a specific resident or household due to one or more of the following: (a) lack of reliable internet access; (b) disability-related barriers; (c) limited English proficiency or literacy barriers; (d) verified financial hardship that materially impacts the resident's ability to obtain or maintain technology access; or (e) other circumstances approved by NWGHA on a case-by-case basis. An Approved Exception documents a household's circumstances and triggers proactive alternative service delivery by NWGHA; it is not a precondition to a resident's use of the non-digital alternatives guaranteed by this policy.
     
     
   • Business Day means any day NWGHA's administrative offices are open to the public, excluding weekends and observed holidays.
     
     
   • Digital Services means all NWGHA-approved electronic platforms and processes used for resident interactions, including but not limited to the tenant portal, the RentCafe online payment platform, online recertification and document submission systems, electronic notices, and any future digital tools implemented by NWGHA.
     
     
   • Legal Notice means any notice for which HUD regulations, Georgia law, or the dwelling lease prescribes a required method of service, including notices of lease termination, notices of adverse action, and rent demands.
     
     
   • Reasonable Accommodation means a modification or adjustment to NWGHA's policies, practices, or procedures that is necessary to afford a person with a disability an equal opportunity to use and enjoy a dwelling unit or to participate in NWGHA programs and services, as required under the Fair Housing Act, Section 504 of the Rehabilitation Act, the Americans with Disabilities Act, and implementing HUD regulations.
     
     
   • RentCafe means NWGHA's designated primary online platform for rent payments, account management, and related resident financial transactions.
     
     
   • Tenant Portal means NWGHA's primary digital platform for routine resident communications, account access, document submission, maintenance requests, recertification, and other housing management functions.
     
     
   • WIPS (Walk-In Payment System) means the alternative payment service designated or authorized by NWGHA for rent payments at authorized retail locations or NWGHA payment kiosks.
     
     
3. General Principles 
   NWGHA adopts the following principles to guide implementation of this policy:
   
   
   1. Voluntary Participation. Use of digital services is encouraged but voluntary. Consistent with HUD guidance (Notice PIH 2020-32) and the E-SIGN Act (15 U.S.C. § 7001(c)): (a) use of electronic signatures, electronic documents, and electronic communications requires the resident's affirmative consent, which may be withdrawn at any time without penalty; and (b) any resident may use paper documents, original ("wet") signatures, and the non-digital payment, submission, and communication methods identified in this policy upon request, without any requirement of prior approval. No resident shall be denied benefits, subjected to adverse action, charged a fee, assessed a late charge, or otherwise penalized solely for declining or being unable to use digital services.
      
      
   2. Meaningful Access. NWGHA shall ensure that all residents have meaningful access to housing programs, services, and communications, including through alternative methods when digital participation is not feasible or is declined.
      
      
   3. Interactive Process. NWGHA shall engage in a good-faith interactive process with residents who request exceptions or accommodations and shall document the process and outcome. While a request is pending, NWGHA will not take adverse action against the household based on non-use of the digital service at issue, and any affected deadline will be extended as reasonably necessary.
      
      
   4. No Retaliation. NWGHA prohibits retaliation against any resident who requests an exception or accommodation, exercises rights under this policy, or files a grievance related to digital access.
      
      
   5. Equity and Non-Discrimination. This policy shall be implemented in a manner that does not discriminate on the basis of race, color, religion, sex, national origin, familial status, disability, or any other protected characteristic, and that affirmatively furthers fair housing.
      
      
   6. Language Access. Consistent with Title VI of the Civil Rights Act of 1964, Executive Order 13166, and HUD's limited English proficiency (LEP) guidance, NWGHA shall take reasonable steps to ensure meaningful access to digital services, notices, and alternatives for persons with LEP, including free oral interpretation, translation of vital documents, and use of platform language features where feasible. Residents will be notified of the availability of free language assistance.
      
      
4. Online Rent Payments
   
   
   • 4.1 - A. Due Date 
     Rent is due on the first (1st) day of each month, in accordance with the resident's Lease Agreement, regardless of payment method.
     
     
   • 4.2 - B. Timeliness - All Payment Methods
     A payment is timely if it is received by NWGHA, or initiated by the resident through RentCafe or at a kiosk or WIPS location, no later than 11:59 p.m. on the fifth (5th) day of the month. The same grace period applies to every payment method; no method carries a shorter deadline than any other. If the fifth day falls on a weekend or observed holiday, payments received on the next Business Day (or initiated electronically by 11:59 p.m. on the fifth) are timely. An electronic payment initiated by the deadline is deemed timely if it subsequently clears; ordinary bank processing time after timely initiation will not cause a payment to be treated as late. Payments completed or received after the applicable deadline shall be treated as late for purposes of late-fee assessment and applicable notices, subject to the Lease Agreement, the ACOP, and Section IV.G.
     
     
   • 4.3 - C. Payment Methods
      
     • Primary method. RentCafe is NWGHA's primary and preferred method for rent payment.
       
       
     • Kiosks. NWGHA may make payment kiosks available at designated locations, including for residents who lack reliable personal access to a computer, internet-enabled device, or internet service.
       
       
     • WIPS and Non-Electronic Methods. Any resident may pay through WIPS or by money order or check delivered or mailed to NWGHA's designated payment address (or such other non-electronic method as NWGHA designates), upon request and without prior approval of an Approved Exception. Residents using an alternative method must follow the payment instructions NWGHA provides for that method.
       
       
   • 4.4 - D. Fees; Guaranteed No-Fee Option 
     At all times, at least one payment method shall be available to every resident at no transaction cost. Because tenant rent in public housing is limited by federal law (42 U.S.C. § 1437a; 24 CFR § 5.628), NWGHA will not condition payment of rent on payment of any fee. Certain optional methods (for example, card payments through RentCafe or retail WIPS payments) may carry a convenience fee charged by the third-party processor. Any such fee shall be disclosed to the resident before the transaction is completed, is voluntary (a no-fee method is always available instead), is paid to the processor and not to NWGHA, and shall never be treated as rent or as an amount owed under the lease.
     
     
   • 4.5 - E. Returned Payments 
     A payment returned for insufficient funds or otherwise dishonored is not a payment. Any returned-payment charge must be authorized by the dwelling lease and shall be assessed and collected only as provided in the lease and 24 CFR § 966.4(b)(3). Following repeated returned payments, NWGHA may require certified funds to the extent permitted by the lease and the ACOP.
     
     
   • 4.6 - F. Requests for Alternative Payment Methods, Exceptions or Accommodations 
     Residents who cannot or prefer not to use RentCafe may use the alternative methods in Section IV.C and may request an Approved Exception or Reasonable Accommodation. Requests may be made orally or in writing, including by a person acting on the resident's behalf where permitted by law. NWGHA will respond and engage in the interactive process as provided in Section VIII.
     
     
   • 4.7 - G. Late Payments and Lease Enforcement 
     Late fees may be assessed only when rent is not timely under Section IV.B, only in the amount authorized by the dwelling lease and the ACOP, and regardless of the payment method the resident uses or declines to use. Failure to use RentCafe or any other digital service is never, by itself, grounds for a late charge or adverse action. Consistent with 24 CFR § 966.4(b)(3), late charges and other charges in addition to rent become due no earlier than two weeks after NWGHA gives the resident written notice of the charge, and are subject to the grievance procedure. Late rent, notices for nonpayment, repayment agreements, and any related lease enforcement action (including any termination for nonpayment, which requires at least fourteen days' written notice under 24 CFR § 966.4(l)(3))) shall be handled exclusively under the Lease Agreement, ACOP provisions, applicable HUD regulations (including 24 CFR Part 966), and due-process procedures. The payment method used does not alter the substantive rules governing nonpayment or termination.
     
     
   • 4.8 - H. Receipts and Account Records 
     Residents paying electronically will receive electronic confirmation; residents paying by other methods will receive a receipt upon request (and automatically for any cash payment at a kiosk or WIPS location). Residents may review their account ledger through the Tenant Portal or by requesting a statement from NWGHA at no charge.
     
     
5. Tenant Portal Usage
   
   
   • 5.1 - A. Enrollment
     
     
     • New Households: New households will be offered portal enrollment, with staff assistance, at or prior to lease signing. Enrollment includes the resident's affirmative consent to electronic communications, which may be declined or later withdrawn without penalty.
       
       
     • Existing Households: Existing households are encouraged to enroll in the tenant portal within sixty (60) days of the effective date of this policy. NWGHA will conduct outreach, hold on-site enrollment events where feasible, and offer enrollment assistance during the transition period.
       
       
     • Non-Enrollment: A household that does not enroll will continue to receive communications and services through non-digital methods and will not be penalized for non-enrollment.
       
       
   • 5.2 - B. Resident Responsibilities 
     All residents shall maintain accurate and current contact information (mailing address, telephone number, and - if the resident has consented to electronic communication - email address) on file with NWGHA and, where applicable, in the portal. Enrolled residents who have portal access are additionally expected to:
     
     
     • Monitor portal communications, notices, account information, and deadlines with reasonable regularity;
       
       
     • Use the portal for routine submissions, document uploads, recertification responses, and other designated functions, unless the resident elects an alternative method under this policy;
       
       
     • Safeguard login credentials, log out after use, and promptly report suspected unauthorized account access;
       
       
     • Use the portal only for lawful purposes and the household's own account.
       
       
   • 5.3 - C. Alternatives for Portal Functions 
     The following alternative methods are available to any resident upon request (and shall be proactively offered where an Approved Exception or Reasonable Accommodation has been documented), as appropriate to the resident's circumstances:
     
     
     • Paper submissions of forms, notices, and documents (in person, by mail, or via designated drop-box);
       
       
     • In-person assistance at NWGHA offices;
       
       
     • Telephone assistance and interviews (with appropriate identity verification);
       
       
     • Staff-assisted portal access and submission (with resident consent and verification of information);
       
       
     • Alternate notice delivery (U.S. Mail, email if authorized by the resident, or other method required by law);
       
       
     • Extended deadlines, alternate formats (large print, audio, Braille, etc.), free language assistance, or other methods approved by NWGHA or required as a Reasonable Accommodation.
       
       No household will be denied benefits, subjected to adverse action, or penalized for using an alternative method or for declining to enroll in or use the portal.
       
       
6. Digital Services and Online Recertification
   
   
   • 6.1 - A. Online Recertification and Document Submission 
     Annual and interim recertifications, income verification documents, and other required submissions may be completed and submitted through the tenant portal or another NWGHA-approved digital platform, or by the alternative methods in Section VI.C. Each recertification notice or request for information shall state all available submission methods. Deadlines shall be the same regardless of submission method, subject to extensions granted under Section VIII. Whatever method is used, residents shall complete all applicable items accurately, provide legible copies of requested documentation, and submit the required information by the stated deadline.
     
     Electronic signatures are accepted consistent with HUD guidance (Notice PIH 2020-32); residents may instead provide original signatures on paper documents upon request.
     
     
   • 6.2 - B. Consequences of Non-Compliance with Recertification Requirements 
     Failure to timely submit required recertification information - by any available method, and absent an extension, Approved Exception, or granted Reasonable Accommodation - may result in processing delays, notices of non-compliance, lease enforcement actions, or termination of tenancy in accordance with HUD regulations (including 24 CFR Parts 5, 960 (including § 960.257), and 966), the Lease Agreement, the ACOP, and applicable due-process and grievance procedures. This policy governs the method of submission and available alternatives; it does not modify or limit the substantive recertification obligations or the consequences of non-compliance established by HUD regulations and the lease. A household's choice not to use digital submission is never itself a ground for adverse action. Before taking adverse action based on a missed recertification deadline, NWGHA will make reasonable efforts to contact the household by at least one non-electronic method.
     
     
   • 6.3 - C. Alternative Methods for Recertification and Digital Services 
     The following alternative methods are available upon request: paper submission of recertification forms and supporting documents; in-person interviews and assistance at NWGHA offices; telephone interviews and assistance with appropriate verification; staff-assisted digital submission; home visits where warranted; extended deadlines (as permitted by HUD regulations and the ACOP); and alternate formats, language assistance, and other reasonable methods approved by NWGHA. Requests may be made orally or in writing, including by a person acting on the resident's behalf where permitted by law.
     
     
7. Notice and Communication 
   Routine communications and reminders may be delivered via:
   
   
   • The tenant portal (when the resident is enrolled and has portal access);
     
     
   • Email or text message (if the resident has authorized electronic communication and provided current contact information);
     
     
   • U.S. Mail or hand delivery
     
     Legal Notices: Legal Notices - including notices of lease termination, notices of adverse action, and rent demands - shall be given in writing and served as required by 24 CFR § 966.4(k)-(l),
     
     Georgia law, and the dwelling lease (i.e., delivered to the tenant or to an adult member of the household, or sent by prepaid first-class mail properly addressed, or such other method as governing law requires). Portal posting, email, or text messaging may supplement, but shall never substitute for, the required method of service.
     
     Residents are responsible for maintaining current contact information on file with NWGHA and in the tenant portal (where applicable) to ensure they can receive communications through the method(s) applicable to them. NWGHA will provide this policy and related notices in accessible formats and with language assistance upon request.
     
     
8. Reasonable Accommodations and Approved Exceptions
   
   
   • 8.1 - A. Legal Compliance 
     NWGHA complies with all applicable accessibility and non-discrimination requirements, including: the Fair Housing Act (42 U.S.C. § 3601 et seq.); Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. § 794) and 24 CFR Part 8; the Americans with Disabilities Act (42 U.S.C. § 12101 et seq.); Title VI of the Civil Rights Act of 1964 and Executive Order 13166; and applicable provisions of 24 CFR Parts 5, 960, and 966 and other HUD requirements. NWGHA will take reasonable steps to ensure its digital platforms are accessible to persons with disabilities, including compatibility with screen readers and other assistive technology, and auxiliary aids and services necessary for effective communication will be provided at no cost to the resident.
     
     
   • 8.2 - B. Request and Processing Procedures 
     Residents may request an Approved Exception or Reasonable Accommodation related to portal use, digital document submission, recertification, rent payment methods, or any other digital service. Requests need not use the words "exception" or "reasonable accommodation."
     
     
     • Requests may be made orally or in writing, at any time, including by a person acting on the resident's behalf where permitted by law; staff shall document oral requests;
       
       
     • NWGHA will engage in a good-faith interactive process to identify appropriate solutions;
       
       
     • Verification of disability or need may be requested only to the extent permitted by law and necessary to evaluate the request, and shall not be requested where the disability and the disability-related need are obvious or already known to NWGHA:
       
       
     • NWGHA will provide a written determination within ten (10) business days (or sooner for time-sensitive matters); if more time is genuinely needed, NWGHA will notify the resident of the status and expected decision date;
       
       
     • While a request is pending, NWGHA will not take adverse action based on non-use of the digital service at issue, and affected deadlines will be extended as reasonably necessary;
       
       
     • Approved exceptions and accommodations remain in effect until circumstances change; residents will not be required to re-justify them on a recurring basis absent changed circumstances;
       
       
     • All determinations and supporting documentation shall be maintained in the resident's file in accordance with applicable privacy and record-retention requirements.
       
       
   • 8.3 - C. Examples of Accommodation and Alternatives 
     Accommodations and alternatives may include, but are not limited to: staff-assisted portal enrollment, navigation, and submission (with resident consent); paper documents and documents in alternate formats (large print, audio, Braille, etc.); qualified sign-language interpreters; extended deadlines for submissions or responses; in-person, home-visit, or telephone alternatives to digital processes; and any other modification necessary to ensure equal access and meaningful participation.
     
     
9. Data Security and Privacy 
   NWGHA employs reasonable administrative, technical, and physical safeguards to protect personally identifiable information (PII) and other sensitive data transmitted or stored through digital services, consistent with HUD requirements (including Notices PIH 2020-32 and PIH 2015-06), National Institute of Standards and Technology (NIST) guidelines, and applicable privacy laws. In addition:
   
   
   • Enterprise Income Verification (EIV) data shall not be transmitted through the tenant portal, email, or other unsecured means, and shall be handled only as permitted by HUD's EIV security requirements;
     
     
   • NWGHA shall require its platform vendors to maintain appropriate safeguards and shall follow applicable breach-notification obligations in the event of unauthorized access to resident data;
     
     
   • Electronic records shall be retained in accordance with HUD and NWGHA record-retention requirements; residents may request copies of documents in their file as permitted by law;
     
     
   • Residents are expected to use strong, unique passwords, safeguard login credentials, log out after use, and immediately report any suspected unauthorized access or security concerns to NWGHA. NWGHA will provide residents with information on safe digital practices upon request or as part of portal enrollment assistance;
     
     
   • Consistent with the Violence Against Women Act (VAWA) and 24 CFR Part 5, Subpart L, NWGHA shall maintain the confidentiality of information relating to victims of domestic violence, dating violence, sexual assault, or stalking, including in digital systems, and shall honor requests for confidential alternate contact methods for safety reasons.
     
     
10. Staff Training and Implementation 
    NWGHA shall provide appropriate training to all staff involved in resident services, recertification processing, rent collection, and digital platform administration. Training shall cover:
    
    
    • This policy and its requirements, including the voluntary nature of digital participation and the distinction between method of submission and substantive compliance obligations;
      
      
    • Proper handling of Approved Exception and Reasonable Accommodation requests, including the interactive process and documentation standards;
      
      
    • Language access procedures and use of interpretation and translation resources;
      
      
    • Use of alternative methods and staff-assisted digital support;
      
      
    • Cultural competency, digital literacy barriers, and sensitivity to residents' circumstances;
      
      
    • Required methods of service for Legal Notices;
      
      
    • Data security, privacy, VAWA confidentiality, and confidentiality requirements.
      
      
11. Monitoring, Compliance, and Recordkeeping 
    NWGHA shall monitor implementation of this policy, including: portal enrollment rates and digital service usage trends; the number, types, and outcomes of Approved Exception and Reasonable Accommodation requests; timeliness of responses to requests and provision of alternatives; language-assistance usage; platform accessibility, fee structures, and vendor security practices; and any complaints, grievances, or fair housing concerns related to digital access. Staff shall document all Approved Exception determinations, Reasonable Accommodation requests and outcomes, alternative methods provided, and related interactive-process notes. Records shall be maintained in accordance with HUD record-retention requirements, NWGHA policies, and applicable privacy laws. NWGHA will periodically review this policy for continued effectiveness, legal compliance, and alignment with resident needs and technological changes, and will report material issues to the Executive Director and, as appropriate, the Board of Commissioners.
    
    
12. Grievances and appeals 
    Any resident who believes they have been adversely affected by a decision under this policy (including denial of an Approved Exception or Reasonable Accommodation), or who has been denied meaningful access to services due to digital requirements, may file a grievance in accordance with the NWGHA Grievance Procedure and applicable HUD regulations (24 CFR Part 966, Subpart B). This includes the right to an informal settlement conference and a formal hearing before an impartial hearing officer. Nothing in this policy limits or waives any resident's due-process rights or grievance rights under the lease, the ACOP, or HUD regulations.
    
    
13. Legal Authority and References 
    This policy shall be administered in accordance with all applicable federal, state, and local law, including but not limited to:
    
    
    • United States Housing Act of 1937, 42 U.S.C. § 1437 et seq. (including 42 U.S.C. § 1437a);
      
      
    • 24 CFR Part 5 - General HUD Program Requirements (including Subpart L, VAWA protections);
      
      
    • 24 CFR Part 8 - Nondiscrimination Based on Handicap in Federally Assisted Programs and Activities;
      
      
    • 24 CFR Part 903 - Public Housing Agency Plans;
      
      
    • 24 CFR Part 960 - Admission to, and Occupancy of, Public Housing (including § 960.257);
      
      
    • 24 CFR Part 966 - Public Housing Lease and Grievance Procedure (including §§ 966.3, 966.4, 966.5, and Subpart B);
      
      
    • Section 504 of the Rehabilitation Act of 1973; Americans with Disabilities Act of 1990, as amended; Fair Housing Act;
      
      
    • Title VI of the Civil Rights Act of 1964 and Executive Order 13166 (limited English proficiency);
      
      
    • Violence Against Women Act (VAWA) and implementing regulations (as applicable to digital communications, confidentiality, and safety planning);
      
      
    • E-SIGN Act, 15 U.S.C. § 7001 et seq., and the Georgia Uniform Electronic Transactions Act, O.C.G.A. § 10-12-1 et seq.;
      
      
    • HUD PIH Notices and guidance on electronic signatures, transmission, and storage (including Notice PIH 2020-32), privacy protection of PII (including Notice PIH 2015-06), digital services, electronic recertification, and accessibility, and successor guidance;
      
      
    • NWGHA dwelling lease; NWGHA Admissions and Continued Occupancy Policy (ACOP); NWGHA Grievance Procedure;
      
      
    • Georgia Open Records Act and other applicable state law.
      
      
14. Adoption, Effective Date, and Transition 
    This policy is effective upon adoption by the NWGHA Board of Commissioners and completion of any required resident-participation process, and supersedes any prior inconsistent policies, procedures, or practices regarding digital services, online rent payments, tenant portal usage, or online recertification. To the extent this policy changes lease terms or rules and regulations, NWGHA shall provide at least thirty (30) days' written notice to residents with an opportunity to comment, consistent with 24 CFR §§ 966.3 and 966.5, and shall adopt any conforming lease addendum and ACOP amendments; NWGHA shall also ensure consistency with its PHA Plan under 24 CFR Part 903.
    
    For existing residents as of the effective date, the portal enrollment transition period in Section V.A begins on the effective date. NWGHA will conduct targeted outreach, provide enrollment assistance, and communicate the availability of alternatives, exceptions, accommodations, and language assistance during the transition period to ensure a smooth and equitable implementation.
    
    
15. Questions and Contact Information 
    Residents with questions about this policy, requests for Approved Exceptions or Reasonable Accommodations, or a need for assistance with digital services, portal enrollment, alternative methods, or language assistance should contact their assigned property manager, the NWGHA main administrative office, or the designated digital services coordinator. Contact information and request forms (where applicable) will be made available on the NWGHA website, in the tenant portal, and at all NWGHA offices.