Last week, HUD published a report titled “Small Area Fair Market Rent Demonstration Evaluation: Interim Report,” which provides preliminary findings from HUD’s Small Area Fair Market Rent (FMR) Demonstration. The Small Area FMR Demonstration is a Demonstration of seven PHAs that have implemented Small Area FMRs in a variety of housing markets to test their effectiveness. The potential adverse impacts to Housing Choice Voucher (HCV) program participants that this report identifies is one of the reasons that HUD suspended implementation of mandatory Small Area FMRs.
While NAHRO is still in the process of reading through and analyzing the report, the key takeaways from it on the imposition of Small Area FMRs are the following: different housing markets are impacted differently; there are more families moving into areas of opportunity; there is a loss of affordable units; and there is an aggregate higher cost burden for families.
The evaluation looks at the effects of Small Area FMRs on 1) potential access to opportunity; 2) actual access to opportunity; and 3) costs and rents. Additionally, the study looks at costs to PHAs. Click below for a brief summary of the evaluation findings.
HUD has revised the July 7, 2017 SPEARS Update that set a reporting deadline of July 31, 2017 for “past due” (2013, 2014, 2015, 2016, & some 2017 report years) reports.
On August 14, 2017, HUD issued a SPEARS Update that extended the reporting deadline for “past due” reports to December 31, 2017. The SPEARS Update is available at https://portal.hud.gov/hudportal/documents/huddoc?id=PHAReportDue8-14-17.pdf.
HUD’s Section 3 office is also aware of issues in submitting adjusted reports (6, 9, or 15 month reports) due to the reporting year switching to the PHA fiscal year. It is anticipated that HUD will update the SPEARS system to correct this issue in the very near future.
More information on Section 3 reporting is available at https://portal.hud.gov/hudportal/HUD?src=/program_offices/fair_housing_equal_opp/section3/section3/spears.
On August 16, HUD announced that the FY2017 Family Self-Sufficiency (FSS) Notice of Funding Availability (NOFA) is available via grants.gov. HUD notes that there are several changes from the FY2017 NOFA, including a revised HUD 52651 Form (now an electronic fillable form), and a 3 percent increase in the maximum salary that may be requested per FSS Coordinator. The maximum salary has increased from $69,000 to $72,000.
A pre-recorded webcast will be made available soon with more information.
FSS applications are due September 15, 2017.
Earlier this morning, HUD sent letters to PHAs suspending the mandatory implementation of Small Area Fair Market Rents (FMRs) for 23 of the 24 metropolitan areas which were originally designated as areas in which PHAs would have to use Small Area FMRs. Small Area FMRs are FMRs calculated by zip code, instead of a wider metropolitan area. Among other concerns, there was widespread concern among industry groups and PHAs that the mandatory imposition of Small Area FMRs would mean that new program participants would receive lower voucher subsidy amounts and without appropriate wrap-around services would be unable to find units in neighborhoods which would receive higher subsidies.
NAHRO has long stressed that the quick imposition of mandatory Small Area FMRs would lead to adverse consequences for program participants and is pleased that HUD listened to NAHRO’s concerns and made implementation of Small Area FMRs voluntary. HUD has only suspended the mandatory imposition of Small Area FMRs. PHAs may still choose to voluntarily apply them, if it is the appropriate action for their program participants and community. All other aspects of the Small Area FMR rule remain in place. The suspension will last until October 1, 2019 (for a 2020 implementation), unless the Small Area FMR rule is changed. The Small Area FMR mandatory implementation remains in effect for the Dallas-Plano-Irving, TX Metro Division.
In a letter to HUD, NAHRO previously suggested suspending the Small Area FMR designation using authority under 24 CFR § 888.113(c)(4)(iii). HUD followed NAHRO’s suggestion and suspended the mandatory imposition of Small Area FMRs using the NAHRO-suggested provision. NAHRO is pleased that HUD recognized the potential adverse impacts to program participants and is following the NAHRO-suggested steps to avoid those consequences. NAHRO looks forward to continuing to work with HUD collaboratively to find solutions to tackle tough problems.
NAHRO’s letter to HUD recommending suspending the mandatory imposition of Small Area FMRs can be found here.
NAHRO’s comment letter to HUD on the Small Area FMR rule can be found here.
On August 10, HUD released Notice PIH 2017-13 (HA)/OHHLHC 2017-01, titled “Guidance on HUD’s Lead Safe Housing Rule Pertaining to Elevated Blood Lead Levels for the Public Housing, Housing Choice Voucher, and Project-Based Voucher Programs.” This Notice provides information to public housing agencies (PHAs), Housing Choice Voucher (HCV) property owners and Project-Based Voucher (PBV) property owners on the required actions they must take when a child in a family receiving HCV or PBV assistance is identified as having an elevated blood lead level (EBLL). On January 13, HUD published its “Requirements for Notification, Evaluation and Reduction of Lead-Based Paint Hazards in Federally Owned Residential Property and Housing Receiving Federal Assistance; Response to Elevated Blood Lead Levels” (Lead-Free) final rule that amended HUD’s lead-based paint regulations (LSHR) on reducing blood lead levels in children under age 6 who reside in federally-owned or -assisted housing that was built pre-1978. The final rule also formally adopted the revised definition of “elevated blood lead levels” (EBLLs) in children under the age of 6 in accordance to the guidance of the Centers for Disease Control (CDC). The compliance date for the final rule was July 13.
Yesterday, HUD released the sixteenth edition of the Worst Case Housing Needs: 2017 Report to Congress which finds that in 2015 there were 8.3 million unassisted very low-income households in the U.S. that were experiencing “worst case housing” by spending more than half of their income on rent, living in severely substandard housing conditions, or both. “Very low-income households” are those earning no more than 50 percent of the area median income (AMI). Overall, the number of households with worst case needs have increased by 41 percent since 2007 and by 8 percent since 2013.
A few highlights of the report include the following: Continue reading
In 2015, supporters of the Low-Income Housing Tax Credit (LIHTC) achieved a major victory with the permanent authorization of the 9 percent LIHTC rate, but a 4 percent housing credit rate remains unauthorized. Senators Maria Cantwell (D-WA) and Orrin Hatch (R-UT) have introduced S.548, The Affordable Housing Credit Improvement Act, to permanently authorize the 4 percent rate and expand the program’s overall allocation authority by 50 percent, allowing more public housing agencies (PHAs) and local redevelopment authorities (LRAs) to access the credit.
Affordable housing stakeholders should take action today and support Sen. Cantwell and Sen. Hatch’s critical legislation by asking your senators to join the bill as co-sponsors and urging them to include this bill in any tax reform agreement that is reached. Help NAHRO achieve its goal of sending 2,500 letters to members of Congress in August. Continue reading
In a press release on Wednesday, HUD announced that it was making $38 million available in fair housing grants to fight housing discrimination. The grants are a part of the Fair Housing Initiatives Program (FHIP), which provides funding to non-profits and other fair housing organizations to help people who have encountered housing discrimination. The due date for these notices of funding availability is September 18, 2017. The grants announced are listed below.
- Education and Outreach Initiative grants (EOI) – grants for organizations that educate the public about their rights under federal law and other organizations that enforce certain local fair housing laws. $7,450,000 available by searching FR-6100-N-21-A on Grants.gov.
- Fair Housing Organizations Initiative (FHOI) – grants to build “the capacity and effectiveness of non-profit fair housing organizations.” $500,000 available by searching FR-6100-N-21B on Grants.gov.
- Private Enforcement Initiative grants – grants for organizations that “conduct intake, testing, investigation and litigation of fair housing complaints.” $30.35 million available by searching FR-6100-N-21C on Grants.gov.
The entire press release can be read here.
Earlier this week, the Department of Housing and Urban Development (HUD) Secretary Ben Carson announced an additional $178.5 million to help hard-hit areas in several states recover from severe flooding that occurred in 2015 and 2016. State grant recipients include Florida, West Virginia, North Carolina, South Carolina, and Texas. This new allocation will be provided through the Community Development Block Grant – Disaster Recovery (CDBG-DR) Program, where HUD has previously provided nearly $947 million in these areas for recovery efforts. The CDBG-DR grants will support a wide range of activities, including housing redevelopment, business assistance and infrastructure repair.
Below is the full list of grantees for this announcement and their allocations to date:
On August 10 at 1:30pm, NAHRO Professional Development will present an e-Briefing on Reasonable Accommodation. NAHRO Faculty Member Dennis Morgan will answer many of questions – What is a “reasonable accommodation?” What are your responsibilities as a housing provider? What if a request would creat an undue financial burden, or fundamentally alter the nature of a program?
Reminder: Whether you're watching alone or with an audience of 100, only one registration per connected device is required, making NAHRO Professional Development's e-Briefings an outstanding value!
Register Online at www.nahro.org/training-calendar.