Yesterday, March 23, HUD published PIH-2017-06, a notice titled “Cash Management Requirements for the Housing Choice Voucher Program.” This notice replaces the previous cash management notice (PIH 2011-67) and “revises the cash reconciliation timeframes and provides additional guidance to MTW PHAs.”
While NAHRO will provide additional coverage of the notice in its the next issue of its newsletter, the Monitor, here are few points from the notice.
- Monthly disbursements are based on the most recent validated Voucher Management System (VMS) Housing Assistance Payment (HAP) costs. Disbursements may be scheduled for one or multiple months at a time. Disbursements will be made on the first business day of the month. The notice provides an example document showing how PHAs will be notified of disbursements.
- HUD assesses national program cost trends and may include small increases or decreases to disbursement amounts to account for increases or decreases in national leasing or other costs.
- PHAs whose monthly costs exceed the scheduled disbursements may submit a request for additional advance to their Financial Analyst at the Financial Management Center (FMC).
- Disbursements will be scheduled for deposit in a PHA’s bank on the first business day of the month.
- At least twice a year HUD will compare a PHA’s actual costs to funds disbursed plus other program revenues (e.g., fraud recoveries). Future disbursements will be adjusted accordingly. HUD will address disbursement shortfalls at a reconciliation at the end of the calendar year. In the end-of-the-year reconciliation, if HAP expenses were less than total HAP disbursement combined with other program revenue and Restricted Net Position (RNP), there will be an offset.
- HUD will process prior period adjustments once in the next year.
- The notice provides a sample document HUD will use following each interim and year-end cash reconciliation.
- Incremental vouchers (i.e., first time vouchers) such as HUD-VASH or tenant protection vouchers will have their funding disbursed in equal monthly amounts according to the effective date and expiration dates of their contracts.
- Excess HAP and RNP are to be deposited in an interest-bearing account and at least once a year, PHAs are required to remit that interest to the Treasury.
- PHAs are still able to access their program reserves for eligible HAP needs whenever necessary by contacting their Financial Analyst at FMC.
MTW agencies are subject to cash management requirements. Non-HAP expenses funded from HAP are not considered for the monthly HAP disbursement calculations. Any MTW PHA that needs more than the calculated amount should contact their Financial Analyst at the FMC for additional disbursement, which may include eligible MTW non-HAP expenses.
Additional coverage on the notice will be forthcoming for members. The notice can be read here.
Earlier this morning, HUD sent an email to Executive Directors with hyperlinks to items mentioned in their 2017 HCV Program Renewal Funding Letter. Due to the brevity of the message, I’ve reproduced it completely below.
Dear Executive Director,
The purpose of this communication is to follow-up on the March 15, 2017 letter regarding the regarding the status of calendar year 2017 Housing Choice Voucher Program’s renewal funding. The letter referenced links to the House and Senate 2017 Bills as well as the Field Offices’ Two-year Forecasting Tool, and it has come to HUD’s attention that the links were not active. Below you will find the links to the House and Senate Bills and to the Two-year forecasting tool.
TBRA Senate Report
TBRA House Report
Forecasting tool link
Thank you for your participation in the HCV program.
The original letter can be found here.
Yesterday, Representative Pat Tiberi (R-OH) and Ways and Means Committee Ranking Member Richard Neal (D-MA) introduced the Affordable Housing Credit Improvement Act of 2017 (H.R. 1661), a comprehensive bill that would strengthen the Low-Income Housing Tax Credit (LIHTC or Housing Credit). This bill serves as the companion legislation to S. 548, which was introduced earlier this month by Senators Maria Cantwell (D-WA) and Orrin Hatch (R-UT). Rep. Hatch is Chairman of the Senate Finance Committee.
Similar to the Senate bill, H.R. 1661 seeks to improve LIHTC through provisions that would streamline and modernize the program, as well as increase financial feasibility for projects and encourage development in underserved areas. The legislation would also support the development of rental units that use the Housing Credit in conjunction with multifamily Housing Bonds, which currently provide important financing to about 40 percent of all Housing Credit apartments.
The House bill has bipartisan support and there are 16 other original co-sponsors, 13 of which are Ways and Means Committee members. Unlike S. 548, the House bill would not phase-in a 50 percent increase to the Housing Credit cap. However, H.R. 1661 takes significant steps to strengthen LIHTC and NAHRO joins the ACTION Campaign (a coalition of over 2,000 national, state and local affordable housing stakeholders) in endorsing this critical legislation, while encouraging Congress to include a cap increase in any final tax legislation.
More information on H.R. 1661 by the ACTION Campaign can found here:
As the 2017 Washington Conference begins this week, we are proud to present NAHRO’s 2017 Legislative and Regulatory Agenda.
This year’s agenda builds on our previous Transition 2017, Legislative and Regulatory Year in Review – 2016 documents. It also serves as an extension of our outreach to the new Congress, which introduces NAHRO and its positions. The 2017 Legislative and Regulatory Agenda provides specific priorities and positions that will guide the NAHRO legislative and regulatory roadmap for the coming year.
This agenda is not intended to catalogue all the efforts and policies that NAHRO will actively pursue in 2017. There are many issues — including ones that may rise in priority as federal policymakers act over the course of the year — that will feature prominently in NAHRO’s efforts on behalf of its members and the communities they serve.
Our most vulnerable citizens find a safe harbor and a place to call home in the work of public housing authorities and community development agencies. NAHRO members will continue to meet the challenge of building stronger communities and ensuring that all Americans have a stable, affordable place to call home in which they can live, grow and thrive.
Please read, review, and share NAHRO’s 2017 Legislative and Regulatory Agenda, and feel free to use it to develop and coordinate your agency, local, county, state and regional legislative and regulatory advocacy plans for 2017.
New and updated legislative and regulatory information is available on the Congressional Relations and Policy & Program Development webpages on the NAHRO website and on the NAHRO Blog.
Today, President Trump released his Budget Blueprint, which provides the first portion of his FY 2018 budget request to Congress. The blueprint released this morning contains devastating cuts to vital HUD rental assistance and community development programs. The President’s budget would provide only $40.7 billion for HUD, which is $6.2 billion or a 13.2 percent decrease from the FY 2017 annualized Continuing Resolution (CR) level. The President justifies these cuts by seeing a greater role for states, local governments and the private sector in addressing community and economic development needs.
Of particular note, the Budget Blueprint only focuses on top level funding and offers very few details on specific program funding levels. Additional information on other program specific funding will we understand be available once the President releases his full budget request in May.
The Budget Blueprint:
- Provides over $35 billion for HUD’s rental assistance programs.
- Eliminates funding ($3 billion) for the Community Development Block Grant program.
- Eliminates funding ($1.1 billion) for HOME Investment Partnerships, Choice Neighborhoods, and the Self-help Homeownership Opportunity Program.
- Provides $130 million to promote healthy and lead-safe homes.
- Eliminates funding ($35 million) for Section 4 Capacity Building for Community Development and Affordable Housing.
- Eliminates funding for the Neighborhood Reinvestment Corporation (NeighborWorks America) and the United States Interagency Council on Homelessness (USICH.)
NAHRO is deeply concerned about and will speak against the proposed zeroing out of the HOME, CDBG, and Choice Neighborhoods programs. All have played an important role in ensuring decent, safe, and affordable housing in safe, vibrant communities. We will also speak out against the defunding of the Interagency Council on Homelessness and NeighborWorks America. Alternatively, we are encouraged that $130 million is included in the Blueprint to promote healthy and lead-safe homes. This is a responsible first step. We support Secretary Carson’s interest and his focus on the health and safety of residents assisted under HUD programs and we will in particular continue to speak about the importance of addressing the backlog of deferred maintenance created by reductions to both the Public Housing Capital and Operating accounts over many years.
While the President’s budget proposal marks an important step that sets the tone for the budget and appropriations process, it is primarily a political document that does not carry the force of law. Congress controls the nation’s purse strings and can choose to adopt or ignore the proposal.
For FY 2018, Congress will release funding allocations for all 12 appropriations bills, known as a 302(b) table. NAHRO urges members to educate and inform decision makers on the critically important need nationwide for HCD funding and the need to approve the highest possible 302(b) allocation for the FY 2018 Transportation, Housing and Urban Development (T-HUD) spending bill. You can make your feelings known by sending a letter of support by signing onto a national letter to appropriators today.
But before Congress can take up FY 2018 appropriation, it must first complete FY 2017 funding. The current CR is set to expire on April 28, 2017 and Congress must either extend the CR or preferably complete a FY 2017 Transportation, Housing and Urban Development (T-HUD) appropriations bill by that date.
Today, March 15, HUD sent a letter to Executive Directors about 2017 Housing Choice Voucher (HCV) renewal funding. The letter purports to provide guidance in HCV Program planning.
The letter notes that the Department would normally have 60 days to calculate a PHA’s funding level after a full-year budget or a full-year Continuing Resolution (CR), but currently the Department has neither a full-year budget nor a full-year CR and is operating under a CR that is a few months long. It is operating under a CR that lasts until April 28, 2017. This partial-year CR makes planning difficult. HUD believes that they will only have definitive budgetary information for FY 2017 in June 2017.
Despite this, HUD has evaluated several situations to provide PHAs with potential guidance in HCV Program planning. The letter notes that in calculating national voucher costs a significant inflation factor was applied. There was at least a 2.58% inflation factor applied to all PHAs. Forty percent of PHAs received a higher inflation factor.
- Scenario 1 – Full Year CR (FY 2016 Appropriation Levels):
- HAP proration – 94% and
- Administrative Fee proration – 77%.
- Scenario 2- Full Year budget passed:
- Using Senate Appropriations bill numbers:
- HAP proration – 97.5% and
- Administrative Fee proration – 80%.
- Using House Appropriations bill numbers:
- HAP proration – 97.5% and
- Administrative Fee proration – 75%. [4:03 pm edit – number corrected.]
The letter states that “a full year CR seems to be the responsible starting point for program operations . . . [and] PHAs should assess their projected leasing and spending starting with the 94% proration . . . [and] model alternative scenarios.” HUD also recommends using the HCV Forecasting Tool and modeling different proration scenarios (the forecast tool defaults to 94% currently).
NAHRO agrees that it is safe assumption to assume a full year CR for FY 2017 in program planning.
The full letter can be read here.
HUD Secretary Ben Carson is confirmed to speak at the 2017 NAHRO Washington Conference. Today is last day to register with $100 discount over onsite registion. Register at: http://www.nahro.org/2017-washington-conference-sessions-speakers
Yesterday, Senator Maria Cantwell (D-WA) and Senate Finance Committee Chairman Orrin Hatch (R-UT) introduced the Affordable Housing Credit Improvement Act of 2017 (S. 548), a comprehensive bill that would strengthen and expand the Low-Income Housing Tax Credit (Housing Credit). This legislation is very similar to the version of the Affordable Housing Credit Improvement Act (S. 3237) introduced by the same Senators last year, but with minor modifications.
Earlier this week, Senator Cantwell released a new report that chronicles the nationwide shortage of affordable housing. In her press release, Senator Cantwell said, “[w]e are facing pressures from all sides: demand for rental housing has increased by 21 percent, but we are building units at the lowest rate since the 1970s. If we do not act to increase the Low-Income Housing Tax Credit-our best way to build new affordable homes-by 2025 over 15 million Americans could be spending half of their income on rent. This is unacceptable.”
S. 548 seeks to take steps towards addressing the affordable housing deficit by increasing the overall Housing Credit authority by 50 percent. The legislation also includes other provisions that would streamline and modernize the Housing Credit, increase financial feasibility for projects, and encourage development in underserved areas. The legislation would also support the development of rental units that use the Housing Credit in conjunction with multifamily Housing Bonds, which currently provide important financing to about 40 percent of all Housing Credit apartments.
S. 548 has bipartisan support on the Hill and there are currently eleven other original co-sponsors to the bill: Senate Finance Committee Ranking Member Ron Wyden (D-OR), and Senators Susan Collins (R-ME), Dean Heller (R-NV), Lisa Murkowski (R-AK), Todd Young (R-IN), Charles Schumer (D-NY), Michael Bennet (D-CO), Cory Booker (D-NJ), Patrick Leahy (D-VT), Jeff Merkley (D-OR), and Brian Schatz (D-HI). Also recently, over 2,000 organizations across the country, including NAHRO, signed on to the ACTION Campaign’s letter to Congress in support of S. 548.
More information on the bill by the ACTION Campaign can found here:
On March 7, HUD issued a Notice PIH 2017-5, “Income exclusion under temporary Census employment and Census access.” The notice emphasizes the importance of accurate census data to the HUD programs and discusses how PHAs and other certain HUD grantees must handle a family’s temporary census income along with providing census workers access to buildings.
HUD regulations require temporary, sporadic, nonrecurring income not to be included in the family income calculation. The notice states, “Under this exclusion, PHAs exclude temporary income payments from the U.S. Census Bureau, defined as employment lasting no longer than 180 days per year and not culminating in permanent employment.” This provision applies to all PHAs and HUD grantees that calculate family income under 24 CFR 5.609.
This notice also reminds building managers to provide census workers access to properties. Specific mention of providing census workers access to properties with federally assisted tenants is also made in the notice.
HUD Oversight and Evaluation Division has posted the latest (2/28/17) UPCS-V conference call for this quarter. The call provided updates about how the UPCS-V Demonstration was proceeding and HUD’s planned next steps.
The conference call can be downloaded here.
For a quick overview of some key points in the conference call, our prior post on it can be found here.