The NAHRO Blog Is Now a Part of the NAHRO Website!

In order to streamline our communications, we’ve incorporated the NAHRO Blog into the NAHRO website. All past blog posts have been archived in the Direct News section, and all future posts will be made and archived on www.nahro.org.

If you’re already subscribed to the NAHRO Blog updates, no need to do anything — you’ll continue to receive emailed updates every time we post an article or notification. If you prefer to receive immediate updates when we post a new article to the NAHRO website, you can subscribe at the bottom of each article. Please note: while anyone can subscribe to receive updates, some articles will be accessible to members only.

HUD Email Provides Information on Voucher Timelines

Earlier today, HUD sent its monthly “The HCV Connect” email. The email emphasized the following points:

  • Housing agencies with voucher programs should finalize their 2023 reporting by January 29th;
  • Moving to Work (MTW) agencies should report MTW eligible activities that the agency has dedicated MTW HCV reserves towards in the Voucher Management System (VMS);
  • HUD will begin revoking and reallocating certain Emergency Housing Vouchers (EHVs) soon based on data as of Feb. 15–if a housing agency is on the list for revocation (see PIH Notice 2023-31), it should try to maximize voucher issuance and leasing;
  • Waive 1 of Enterprise Voucher Management Systems (eVMS) PHAs have successfully received their voucher disbursement through the new system–all PHAs are encouraged to review and utilize the PIC Error Dashboards to prepare for the eVMS migration;
  • HUD has published FAQs for Stability Vouchers;
  • If PHAs wish to continue using HQS instead of NSPIRE, they should have notified HUD by Nov. 15, 2023 and all unvented, fuel-burning space heaters should have been removed as of Jan. 1, 2024;
  • HUD hosts voucher utilization webinars every Thursday of every month; upcoming topics include End of Year Reconciliation and Special Purpose Vouchers and Review of HCV Landlord Engagement Resources;
  • Old HUD Utilization webinars can be found here;
  • HUD will hold a small area Fair Market Rent (FMR) virtual convening on Feb. 21, 2024; and
  • Updated 2024 funding estimates have been entered into the two-year tool.

HUD Releases Proposed Rule to Revise CDBG and Section 108 Program Regulations

On January 10, HUD published a proposed rule that would revise the Community Development Block Grant (CDBG) and related Section 108 loan guarantee program regulations.

Proposed changes will not have any impact on the allocation of CDBG funds among recipients. Additionally, HUD asks for comments to 11 questions provided within the proposed rule.

Comments to the proposed rule are due by March 11, 2024 and can be submitted here.

According to HUD, the proposed rule is meant “to provide authority that would allow CDBG grantees and Section 108 borrowers to implement funding more effectively and efficiently in their communities.” In addition, HUD believes the proposed changes would enhance the goals of the CDBG program to benefit low- and moderate-income (LMI) persons and remove obstacles that prevent it’s effectiveness.

The proposed rule would make some of the following changes and updates:

  • Proposes change to national objectives criteria to remove impediments to carrying out economic development activities.
  • Updates the public benefit standards to allow CDBG and Section 108 recipients greater flexibility in undertaking economic development activities.
  • Incorporates several changes to eligible activities under the CDBG and Section 108 programs.
  • Aims to simplify regulations to encourage CDBG and Section 108 recipients to invest CDBG funds in underserved communities.
  • Adds methods of making the Consolidated Plan publicly accessible to persons with disabilities and provide meaningful access to limited English proficient persons.
  • Proposes changes to Indian Community Development Block Grant (ICDBG) regulations related to eligibility activities and other various definitions to ensure that CDBG and ICDBG regulations are in alignment.
  • Aims to remove outdated provisions and make technical corrections.
  • Revises and adds definitions, such as period of performance, mixed use property, labor market area and many more.

For more information, see the proposed rule or the February edition of The NAHRO Monitor.

HUD Posts Proposed Changes to Methodology for Calculating Section 8 Income Limits

On January 9, HUD posted a pre-publication copy of a notice in the Federal Register titled “Changes to the Methodology Used for Calculating Section 8 Income Limits under the United States Housing Act of 1937.” Since Fiscal Year (FY) 2010, in calculating the thresholds for “low-income families” and “very low-income families,” HUD has limited the increase from one year to the next as the higher of either five percent or twice the percentage change in the national median family income. The Department also does not allow income limits to decrease by more than five percent from the previous year. This notice proposes adding an additional requirement that the annual income limits never increase by more than 10 percent per year and also proposes changes to the definition of national median family income.

The Department has identified two rationales for limiting income limit increases and decreases. The first is that the American Community Survey (ACS)–which is used to calculate area median family income estimates–is subject to error and may fluctuate despite the underlying median income staying the same. The second reason is that certain programs, such as the Low-Income Housing Tax Credit (LIHTC), use the income limits to determine rent for low-income families and by limiting decreases, HUD helps to ensure that certain properties remain financially viable. Similarly, by limiting increases, HUD helps to ensure that low-income families do not face large rent increases very quickly.

The Department would also like to calculate the national median family income by using “the most recent unadjusted estimates of median family income provided by the Census Bureau via the ACS.” The Department states that “[b]y continuing to remove inflation adjustments from its cap calculation, HUD is keeping the calculation in line with its purpose of capturing trends in median family income data addressing survey volatility rather than volatility introduced by accelerating or decelerating inflation.”

Comments on the proposed changes will be due 30 days after the notice is published.

The full pre-publication copy of the notice, including questions to which HUD is looking for responses, can be found here.

HUD Publishes Notice Detailing Public Housing Operating Fund Shortfall Grant Reporting

HUD has published Notice 2024-02pihn, “Shortfall Grant SF-425 Reporting Requirements.” In each fiscal year (FY) from 2020-2023, HUD has distributed $25 million per year in Public Housing Operating Fund Shortfall grants. The original grant information for FY 2020 and 2021 did not require agencies to provide a report for this funding; however, Notice 2024-02 clarifies that grant recipients for any years between 2020 and 2023 must submit an SF-425 for each year they received this funding. The notice discusses the following based on the year agencies received funding:  the period of performance, due dates for the SF-425, obligation and expenditure dates, and LOCCS policies. The first SF-425 submissions due are April 30, 2024 for FY 2022-2023 awards, and these two years will require annual submissions. 2020 forms are due in April 2025 and 2021 forms due in April 2026.

For more information on the Operating Fund Shortfall notice and context, see the January 15 edition of The NAHRO Monitor or 2024-02pihn.

HUD Implements HOTMA Section 103 Waiting List Requirement via New Online Module

Waiting List Submissions Due March 31, 2024

On January 3, 2024, HUD continued implementing Section 103 of the Housing Opportunity Through Modernization Act (HOTMA) by opening the Public Housing Waiting List Module. A major component of Section 103, agencies must report to HUD the number of families on their public housing waiting list(s). HUD will use this module to collect and publish data waiting list lengths. As in other communications about this data collection, HUD reminds agencies to report each family on waiting lists once and not to report the same family more than once if they are on multiple waiting lists.

The module is available via the Public Housing Portal. HUD’s January 3 communication regarding the portal includes the “PHA Public Housing Waiting List User Guide,” “Public Housing Waiting List Submissions” training video, and resources and deadlines for other public housing programs.  

HUD Releases BABA Guidance    

HUD’s Office of Public and Indian Housing has released “Build America, Buy America Act Implementation Guidance for the Public Housing Program,” PIH Notice 2024-01. This notice is separate from guidance from both HUD’s Office of Community Planning and Development and the Office of Management and Budget (OMB) regarding the Build America, Buy America Act (BABA). The guidance synthesizes the steps HUD and OMB have taken to implement the law and clarifies remaining compliance questions. BABA is being implemented in phases, and agencies do not yet need to comply with the law for many programs.

The notice answers several pending questions about complying with BABA:

  • Definitions, several of which were determined by OMB rulemaking,
  • How the BAP will apply to ongoing projects,
  • Steps agencies should take to ensure their own and their partners’ compliance with BABA,
  • Determining which projects must comply with the law,
  • Situations in which BABA applicability for specific funding changes over time,
  • Documenting purchases and efforts to comply with BABA, and
  • Requirements for submitting a waiver to HUD.

For more information, see the notice or the January 15 edition of The NAHRO Monitor.

HUD Institutes Cash Management Practices for the EHV program

On Dec. 19, HUD published a notice titled “Cash Management and Closeout Procedures for the Emergency Housing Vouchers (EHV) Program funds, and Supplemental Information Regarding EHV Contract Renewal Calculation.” The notice establishes cash management procedures for PHAs with EHVs. These vouchers are for households that are homeless; at risk of homelessness; fleeing or attempting to flee domestic violence, dating violence, sexual assault, stalking or human trafficking; or recent homeless or have a high risk of housing instability.

The Department will distribute EHV funds in accordance with Treasury cash management procedures. It will make monthly or multi-month disbursements based on the most recent month of validated EHV Housing Assistance Payments (HAP). Excess HAP will be held in HUD-held reserve accounts. Undisbursed amounts will likely be offset in the next year. Moving to Work agencies will be subject to these cash management processes.

The full notice can be found here.

HUD Reopens Jobs Plus Notice of Funding Opportunity

Applications due March 12, 2024

HUD has reopened the FY 2023 Jobs Plus NOFO to distribute remaining funding amounts from fiscal years 2023-2024 until March 12, 2024. Applicants can find this grant opportunity on grants.gov, and more information is available on the FY 2023 Jobs Plus NOFO webpage, including a full Program NOFO, FAQs, and instructions. PHAs that did not submit an application by the August 21, 2023 deadline may apply, and agencies that applied by the that deadline do not need to submit another application. PHAs who received a Jobs Plus award from FY 2019 or earlier may apply again. In their announcement, HUD “strongly encouraged” agencies to apply who have not received a Jobs Plus award previously or did not apply by the August deadline.

HUD Releases 2023 Annual Homelessness Assessment Report

On December 15, HUD Released part one of their Annual Homelessness Assessment Report (AHAR), which revealed a 12% increase in the number of individuals experiencing homelessness on a single night compared to 2022.

According to HUD, this is highest number of people reported to be experiencing homelessness on a single night since 2007 when reporting began.

The report, which is conducted every year, provides a glimpse into the number of individuals in shelters, temporary housing, and in unsheltered settings. More than 650,000 people were found to be experiencing homelessness on a single night in January 2023. Six in ten people experienced homelessness in shelters while the remaining experienced unsheltered homelessness.

Demographics of Homelessness in 2023

In 2023, the report shows that people who identify as Black or Indigenous continue to be overrepresented among the population
experiencing homelessness. Of the total number of those experiencing homelessness in the U.S., 37% identified as Black, African American, or African. Additionally, those who identified as Indigenous had the largest percentage increase in sheltered homelessness by 18% or 1,631 more people.

Of those experiencing homelessness, 72% experienced homelessness in households without children. More than 34,700 unaccompanied youth under the age of 25 were found to experiencing homelessness as well (a 15% increase from 2022). Veterans experiencing homelessness saw a 7% increase raising the total to 35,574 in 2023.

Continuums of Care (CoC)

According to data received from 381 CoCs, more than 52% of all people experiencing homelessness in the United States were located in the top 50 largest cities. This is 50,277 more people than 2022. While this may be the most notable increase, homelessness increased across all geographic categories in 2023.

The rise in homelessness also meant a rise in bed inventory. Between 2022 to 2023, bed inventory increased for those currently experiencing homelessness by 7% and for those formerly experiencing homelessness by 6%. This inventory increased across all rapid rehousing, permanent supportive housing, and other permanent housing programs.

For the full report, please see here.