On October 23, HUD published a notice titled “Implementation of Section 209(b) of the Economic Growth, Regulatory Relief, and Consumer Protection Act (Economic Growth Act)” (PIH 2020-30). This notice implements an energy savings program for small, rural PHAs that was created by the Economic Growth, Regulatory Relief, and Consumer Protection Act (Economic Growth Act). The National Association of Housing and Redevelopment Officials submitted comments on implementing section 209(b). Our comments stated that this program should be distinct from Energy Performance Contracting, that the program should be easy to apply to and to administer, and that PHAs should have flexibility in how they use the savings. We are pleased that HUD closely followed many of NAHRO’s suggestions. The program—called the Small Rural Frozen Rolling Base (SR-FRB)–would allow eligible PHAs to freeze the cost of their energy consumption levels, improve their energy efficiency, and use any cost savings for any eligible public housing purpose at the PHA’s discretion. This program differs from Energy Performance Contracting (EPC) in that it is much easier to apply to and administer.Continue reading
Earlier today, HUD’s Financial Management Division (FMD) emailed PHAs to remind them that they need to ensure PHA Executive Directors possess the OPD – PHA Executive Director user role in the Operating Fund Web Portal. The director must have this role to certify and submit PHA forms SF-424, HUD-50071, and, if required, SF-LLL to HUD. WASS coordinators assign user roles, and only the Executive Director should be assigned OPD – PHA Executive Director. WASS coordinators should refer to the following user guide for instructions on how to assign the role. PHA Executive Directors and staff can review their assigned user roles by logging into the Operating Fund Web Portal and clicking the “roles assigned” button.
On October 16, HUD published a notice titled “Guidance for Running an Optimized Housing Choice Voucher Program” (PIH 2020-29). The notice warns of increasing reserves nationally and notes that an optimized Housing Choice Voucher (HCV) program maximizes the number of families served, while minimizing rent burden. The notice discusses several program tools such as the Two-Year Forecasting Tool, the Payment Standard Tool, the HCV Analysis Tool and PIC Drill-Down, and the HCV Guidebook. The notice also discusses the voucher program planning timeline and best practices to increase success rates.
The full notice can be found here.
In August, NAHRO hit a major advocacy milestone by sending nearly 13,000 letters to Congress and the White House urging support for affordable housing and community development programs. So what? What impact does sending a bunch of pre-written letters actually have?
Sending letters can be frustrating. Sometimes when you send a letter, you do not hear back. If you do hear back, often you receive a canned response that does not directly address the points you raised in your letter. Don’t be dismayed- your letter actually has an impact in Congressional offices, even if you don’t see it.
What Happens to Your Letter?
Once you hit “send” in NAHRO’s Advocacy Action Center or on the Advocacy Center App, your letter is emailed straight to your lawmaker. Each Congressional office is different, but typically an intern or a lower-level staffer will read each and every correspondence they receive, whether it be a hand-written note that is mailed through USPS, an email sent to the office, or a comment submitted to their web site. That staffer will make note of the topic of your letter and file it away. Offices receive a significant number of letters each day, so this process can take time, especially now.
Tip: During COVID-19, many offices have not been hiring interns, which means your letters have been read by permanent office staff. Though these staffers are likely lower level, these staff frequently are promoted within the office to take on more responsibility and legislative work. That means your letters during the pandemic could have an even larger impact on offices.
Why Did I Receive That Response?
The staffer who reviews your letter will also select a response to send back to you. These response messages are pre-drafted and approved by your lawmaker. Since offices receive so many letters, offices can’t address every single topic they are contacted about, which is why sometimes the email you receive back doesn’t quite match what you wrote to them about. Don’t get frustrated by this – get motivated!
Tip: Unless you took the time to edit the letter in NAHRO’s Advocacy Action Center (which you can do, and which we encourage!), you also sent your lawmaker a pre-drafted, non-personalized letter. So, receiving a non-personal response is fair.
Why Did We Ask You to Send So Many Letters?
The reason why we focus so much on letter goals during our advocacy campaigns is because within Congressional offices, volume matters. The more people who contact a Senate or House office about things like Section 8 Administrative Fees, the more likely the office is to actually think about what that funding does and form policy positions around the topic.
Your letter was one of 13,000 and helped to elevate affordable housing and community development within offices. Every single letter matters, even if you don’t always see how. Your letter may have pushed Congressional offices to:
- Have a conversation with the boss: Step one to getting an office to prioritize affordable housing is to get them thinking and talking about it. If you and your colleagues sent enough letters on voucher access or the Public Housing Capital Fund, the staff will alert the member of Congress that their constituents (the people who they represent in their states or Congressional districts) are talking about this issue. If the office doesn’t know enough about the topic, this can push staffers to do more research and be prepared to brief their boss. Your letters help create awareness and understanding of affordable housing policy in offices.
- Draft a specific response letter: NAHRO’s more seasoned advocates have noticed a trend in the past couple years: the pre-drafted responses to their letters they are receiving are beginning to actually address specific HUD programs rather than housing or federal funding in general. Many offices have a specific number of letters they need to receive on any given topic to draft a response to it. In the past, letters on things like Section 8 vouchers or public housing would elicit responses like “I too care about homeownership.” Not quite right. Now, we’re seeing some responses that actually articulate support for things like increasing funding for the Capital Fund. Your letters are working.
Tip: Because of the volume of letters sent in August, while you may have received a slightly off topic response over the summer, since then offices may have changed their housing responses. Try contacting your Congressional offices again to see if you sent enough letters to change their response!
- Consider Being More Active in Housing: If members of Congress think that their constituents care deeply about certain topics, that impacts the decisions they make as individual members of Congress. This can result in a lawmaker doing things like giving speeches about housing, choosing to publicly support housing legislation, drafting housing legislation, or even joining a Congressional committee that makes decisions about housing policy. The more their constituents care, the more likely the member of Congress is to prioritize housing when making these decisions. Your letters help communicate that affordable housing matters in your community. This is how we build future champions for affordable housing in Congress.
Want to Do More?
If you’re ready to take the next step in advocacy, consider calling your lawmakers’ Washington, DC offices to follow-up on your letter. You can find their office number on their web site or you can be connected directly through the Capitol switch board: 202-224-3121. When you call, ask to speak with their housing staff. Introduce yourself and your agency, ask if they’ve seen a copy of your letter (they may not have), and briefly discuss how the highlights of the letter relate back to your agency and your work. If you need more help honing your messaging before calling offices, contact NAHRO’s Director of Congressional Relations Tess Hembree (firstname.lastname@example.org).
Our Letters Work
Your letters create higher funding levels and meaningful policy changes for HUD programs. Since FY 2018, HUD funding has been increased every single fiscal year, even during extremely difficult fiscal climates. You’ve affected the first legislation that specifically addresses the challenges of small public housing authorities. Your letters even helped end the longest government shutdown in history.
So next time you send a letter but don’t see an immediate impact, remember that every single letter raises awareness of affordable housing and community development in Washington, DC. Thank you for doing your part.
The Department of Housing and Urban Development (HUD) published a rule titled “Housing Opportunity Through Modernization Act of 2016—Housing Choice Voucher (HCV) and Project-Based Voucher Implementation; Additional Streamlining Changes.” This rule does four things. First, it changes regulatory code to implement Housing Opportunity Through Modernization Act of 2016 (HOTMA) provisions that were previously implemented via notice. Second, it proposes to implement additional provisions of HOTMA that have not yet been implemented. Third, it proposes several regulatory changes unrelated to HOTMA. Fourth, the rule proposes removing “obsolete regulatory provisions.” Comments for these proposed changes are due December 7, 2020.
There are several new HOTMA-related topics and non-HOTMA-related topics that this proposed rule is seeking to implement. Among the new HOTMA-related topics that this rule will implement include enforcement of housing quality standards, manufactured home space rental, entering into a project-based voucher (PBV) housing assistance payment (HAP) contract without an agreement to enter a HAP (AHAP) contract, providing rent adjustments using an operating cost adjustment fact (OCAF), owner-maintained site-based waiting lists, and environmental requirements for existing housing. Among the non-HOTMA-related topics touched by this rule are changes that HUD characterizes as clarifying and simplifying the program rules.
Staff at NAHRO are still in the process of reading through the proposed rule. Additional information will be forthcoming.
The rule can be found here.
Earlier today, HUD published a notice titled “Foster Youth to Independence Initiative” (PIH 2020-28). This notice discusses how any PHA which meets certain eligibility requirements (including those agencies that already have a Family Unification Program) may apply for additional Family Unification Program vouchers for youth aging out of foster care. This supply of vouchers is funded through a $10 million set-aside in the 2020 appropriations act.
NAHRO members will receive additional information on this notice.
The full notice may be found here.
The Department of Housing and Urban Development (HUD) has published a new chapter–titled “Technology“–as a part of its Housing Choice Voucher (HCV) Landlord Strategy Guidebook for PHAs. The goal of the guidebook is to “share strategies that public housing agencies (PHAs) can implement to improve landlord participation in the HCV program.” This chapter is divided into four sections. The first three sections discuss creating a HCV landlord webpage, creating a HCV landlord portal, and inspections technology. The fourth section is an appendix with information and sample content.
NAHRO members will receive additional information on this newly published chapter.
Earlier this summer, HUD published a notice titled “CARES Act – Housing Choice Voucher (HCV) Program Housing Assistance Payments (HAP) Supplemental Funding” (PIH Notice 2020-17). This notice allows for PHAs to apply for additional CARES Act funding for significant increases in per unit cost (PUC) due to extraordinary circumstances. Applications for this funding must be submitted by October 31, 2020.
If a PHA has previously submitted applications for calendar year (CY) 2020 HAP renewal set-aside funding under the “Unforeseen Circumstances” category due to PUC increases caused by COVID-19, the PHA must resubmit according to instructions in this new notice. For those who submitted under the “Unforeseen Circumstances” category for other reasons, they are not required to resubmit, but may do so if their PUC has further increased because of COVID-19.
Public Housing Agencies must meet certain requirements to access this funding. First, applications must be submitted by Oct. 31, 2020. Applications will be reviewed by HUD on a rolling basis. Second, to be eligible, a PHA must have a PUC that is 102 percent or greater than the PUC HUD used to determine the PHA’s CY 2020 renewal funding. The PHA must also meet the submission requirements detailed in the notice.
The PHA will also receive a priority status. If the PHA’s HAP reserves contain an amount that is less than the amount needed to cover 3 months of HAP expenses, the PHA will qualify for priority status. Public housing agencies qualifying for priority status will receive funding shortly after their application is processed, subject to funding availability. Those agencies that receive regular priority will receive notification that their application has been approved, but funding will not be made until November.
|Group||Complete Application||PUC > than 102%||HAP Reserve < 3 months|
|Priority||Eligible for Immediate funding||Yes||Yes||Yes|
|Regular||To be funded in Nov. 2020||Yes||Yes||No|
|Ineligible||Ineligible for Funding||No||No||N/A|
To be eligible for funding, a PHA must submit a completed Appendix B in the notice to 2020COVIDHCV@hud.gov.
These funds may not be rolled into restricted net position (RNP) and must be tracked and accounted for separately through the period of availability.
Earlier today, HUD published PIH 2020-26, titled “Rental Assistance Demonstration (RAD) – Supplemental COVID-19 Guidance.” This notice does two things. First, in obligating operating funds for a RAD conversation in the first calendar year in which a housing assistance payment (HAP) contract is effective, this notice states that the project is eligible to receive up to the CARES Act operating fund grant amount provided (prorated by the number of ACC units converted and removed from PIC). Second it provides flexibilities for PHAs in conducting required resident meetings prior to conversion until Dec. 31 2020 due to the COVID-19 emergency.
Members of NAHRO will receive additional information on this notice.
The full notice can be found here.
On September 18, HUD pre-published the “Streamlining and Implementation of Economic Growth, Regulatory Relief, and Consumer Protection Act Changes to Family Self-Sufficiency (FSS) Program” proposed rule. The Economic Growth, Regulatory Relief, and Consumer Protection Act amended HUD’s FSS program including changes to the size calculation for the FSS program, expanding the definition of eligible family to include tenants of certain privately owned multifamily projects subsidized with Project-Based Rental Assistance (PBRA), updating the FSS Contract of Participation (CoP), reducing burdens on Public Housing Agencies (PHAs) and multifamily assisted housing owners, clarifying escrow account requirements, and updating the program coordinator and action plan
requirements. Comments are due 60 days from publication in the Federal Register.