HUD Sends Letter Confirming Operating Fund Proration

Earlier today, HUD sent a letter explaining Public Housing Operating Fund obligations for June. In June, HUD is increasing the proration for the Operating Fund from 85 percent to a 92.89 percent proration.

The proration represents a cumulative amount for the year. Since PHAs received payments based on a lesser yearly proration for the first few months of the year, June’s payment will be greater to compensate for the initial underfunding. The July payment will more accurately represent the new monthly amount under the new proration. The letter notes that there may be minor proration flucuations and that “[t]he final proration will be established after final eligibility is determined for all projects.”

A change in proration is only one reason that a PHA’s payment in absolute terms (i.e., actual amount received) may have changed. Another reason for a change in the absolute amount is a decline in formula eligibility for some PHAs. Read more about this formula eligibility decline in our previous post “Operating Fund Proration Increases as Funding Decreases.”

Specific June Operating Fund obligation letters grouped by state can be found here.

HUD’s letter explaining June Operating Fund obligations can be found here.

HUD to Propose FMR Methodological Changes

Tomorrow, HUD will publish, in the Federal Register, a notice titled “Proposed Changes to the Methodology Used for Estimating Fair Market Rents.” The Housing Opportunity Through Modernization Act of 2016 (HOTMA) requires HUD to seek comment for material changes to FMR methodology. Responding to NAHRO’s prior comment letter, HUD has agreed to an expansive definition of what constitutes a material change. This notice follows through on HUD’s agreement to seek comment on changes. Comments will be due 30 days after tomorrow’s publication. [5/26/17 Edit – Comments are due June 26, 2017.]

HUD currently calculates FMRs by assigning each area a two-bedroom standard quality base rent from a five year American Community Survey (ACS) tabulation. The base rent is then updated with a recent mover adjustment factor from the latest one year ACS data. The recent mover factor is adjusted “to be ‘as of'” the year which the FMRs are being calculated by using local or regional Consumer-Price-Index-measured changes in gross rents for two years and then a nationally forecasted trend factor measuring estimated expected growth for another two years.

HUD proposes three changes to the FMR methodological method. The first two changes apply to all FMRs, while the third applies only to Small Area FMRs.

  1. HUD is proposing to only use an ACS estimate, if each ACS estimate is based on at least 100 survey responses. This is in addition, to the current criterion, where HUD only uses the estimate if the error of the estimate is less than half the size of the estimate. If the data does not meet both criteria, then HUD will use an average of the three most recent years of data.
  2. HUD is proposing a change to the “recent mover factor” where HUD uses “all-bedroom” recent mover rents, when the two-bedroom recent mover rents are not statistically reliable.
  3. HUD is proposing moving away from the “ratio” method used to tabulate Small Area FMRs to using gross rent estimates calculated by ZIP Code Tabulation Areas.

HUD will make documentation of the impact of these methodological changes and hypothetical FY 2017 FMRs available. (If they are not posted, they should be posted within the next 24 hours.) NAHRO will continue to examine these methodological changes and discuss it with our membership before coming to any conclusions about their effectiveness in creating more accurate FMRs.

When posted, hypothetical FY 2017 FMRs calculated using the new methodology and hypothetical FY 2017 Small Area FMRs calculated using the new methodology can be found here and here respectively.

The pre-publication notice can be found here.

[5/26/17 Edit – The published document can be found here.]

Proposed Cost Savings Do Not Account for $1.8135 Billion Cut to Public Housing Program

Released on Tuesday, May 23, President Trump’s proposed budget includes significant cuts to the Public Housing Program, especially regarding the Operating and Capital Funds. Although the budget also proposes a set of policies aimed at reducing costs of operating the Public Housing program, these policies would not account for the combined $1.8135 billion cut proposed to the program by the administration. These cuts would only increase the challenges already faced by PHAs across the country in ensuring low-income seniors, families, veterans, and disabled individuals continue to have to access to safe, secure, affordable housing.

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FY 2018 President’s Proposed Budget: Some HCV Thoughts

The following post is meant to offer a few thoughts on the treatment of the Housing Choice Voucher (HCV) Program in the FY 2018 President’s proposed budget. For a deeper analysis, please read NAHRO’s article, “FY 2018 President’s Budget Request: Section 8 Programs” (NAHRO members only). The proposed budget has the potential to affect the HCV Program in two important ways: by cutting funding and by making many policy changes.

Click on the link to read more.

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FY 2018 Proposed Budget: Process and In-Depth Analysis

The Administration’s budget proposal, released on May 23, is the first step in a months-long journey. Now that the Administration has released its recommendations, this Direct News will provide in-depth coverage of how it would affect the Community Development, Section 8 and Public Housing programs administered by HUD.

The budget proposal requests cuts, which if implemented, would be devastating for communities. NAHRO strongly opposes the President’s budget proposal and will work to provide necessary and responsible funding for critical housing and community development programs. NAHRO will also fight for long-overdue program and regulatory reforms that can reduce costly administrative burdens.

Members should note that the President’s request is the beginning and not the end of the budget and appropriations process. The Administration’s budget request has over the years become a political document that reflects the fiscal goals and priorities of the Administration for the upcoming fiscal year. It does not carry the force of law. Congress, who controls the nation’s purse strings, can choose to accept the request wholesale, pick and choose parts of it, or reject it outright, which they frequently do. NAHRO will fight to ensure that work undertaken by our members to address critical housing needs for vulnerable families can be sustained.

NAHRO’s initial review can be found in The NAHRO Blog’s post, “President Officially Releases FY 18 Budget Proposal, Slashes Housing and CD Spending.” NAHRO members click on the links below to review the in-depth FY 2018 budget request analysis for Community Development, Section 8, and Public Housing:

Community Development (NAHRO Login Required)

Section 8 (NAHRO Login Required)

Public Housing (NAHRO Login Required)

President Officially Releases FY 18 Budget Proposal, Slashes Housing and CD Spending

The President’s FY 2018 budget request was officially released today.

The proposal, which largely mirrors the budget preview released in March makes steep cuts to housing and community development programs, slashing the overall HUD budget by $6 billion. The bulk of the cuts are to community development programs, which are largely eliminated. The budget also cuts the Public Housing Capital Fund by 68 percent, requesting a funding level of just $628 million for the upcoming fiscal year. The budget document also mentions that the Administration is working toward a “comprehensive package of rental assistance reforms” including “increased tenant rent contributions, the establishment of mandatory minimum rents, and the end of utility allowance reimbursements, among others.”

These proposed cuts, if implemented, would be devastating for communities. NAHRO strongly opposes the President’s budget proposal and will work to provide necessary and responsible funding for critical housing and community development programs. NAHRO will also fight for long-overdue program and regulatory reforms that can reduce costly administrative burdens. Listed below are the Administration’s proposed 2018 funding levels for programs central to the work of NAHRO’s membership.

  • Public Housing Operating Fund: $3.9 billion, $500 million less than FY 2017
  • Public Housing Capital Fund: $628 million, $1.31 billion less than FY 2017
  • Choice Neighborhoods: $0, $137.5 million less than FY 2017
  • Tenant-Based Rental Assistance: $19.318 billion, $974 million less than FY 2017
  • Section 8 Housing Assistance Payment Renewals: $17.584 billion, $771 million less than FY 2017
  • Ongoing Administrative Fees: $1.54 billion, $100 million less than FY 2017
  • Family Self-Sufficiency: $75 million, level funding from FY 2017
  • Section 8 Project-Based Rental Assistance: $10.751 billion, $65 million less than FY 2017
  • Community Development Block Grant: $0, $3 billion less than FY 2017
  • HOME Investment Partnerships Program: $0, $950 million less than FY 2017
  • Housing Opportunities for Persons with AIDS: $330 million, $26 million less than FY 2017
  • Homeless Assistance Grants: $2.25 billion, $133 million less than FY 2017
  • National Housing Trust Fund: $0, approximately $219 million less than FY 2017

Members should note that the President’s request is the first step in the budget and appropriations process. The Administration’s budget request has over the years become a political document that reflects the fiscal goals and priorities of the Administration for the upcoming fiscal year. It does not carry the force of law. Congress, who controls the nation’s purse strings, can choose to accept the request wholesale, pick and choose parts of it, or reject it outright, which they frequently do.

Though the budget preview released in March was largely rejected by members of Congress, it is still important to communicate to your members of Congress the impact these types of cuts would have in your community.

This year’s budget comes months later than the traditional budget release date of the first Monday in February, placing a serious time constraint on Congress to approve as many appropriations bills as possible prior to leaving Washington for the August recess. Typically, by this time in the year, cabinet agency funding bills for 2018 would have already been approved. For example, the Senate passed the FY 2017 Transportation, Housing, and Urban Development (T-HUD) spending bill on May 19, 2016. Because of this shortened timeline, it is largely expected that a continuing resolution (CR) will be necessary to keep the government functioning beyond the end of the fiscal year on September 30.

Detailed coverage of the 2018 HUD budget request will follow later this week, which will give the membership more specific information and analysis that will assist you in educating and inform decision-makers and other interested parties.

NAHRO’s Policy Points on the MTW Expansion Operations Notice

On May 4, HUD reopened the comment period of the January 23, 2017 Moving to Work (MTW) Operations Notice for an additional 30 days. NAHRO has put together a document discussing our policy points to help orient interested parties’ comment letters to HUD. The document focuses on NAHRO’s responses to the specific topics HUD inquired about in their solicitation of comments in January. Comments are due June 5, 2017.

NAHRO’s policy points can be found here, and NAHRO’s initial comment letter submitted to HUD in March can be found here.

 

 

HUD Publishes Violence Against Women Reauthorization Act of 2013 Guidance

On May 19, HUD Office of Public and Indian Housing (PIH) published a new notice (PIH-2017-08) that provides guidance to PHAs and owners on the requirements of the “Violence Against Women Act of 2013: Implementation in HUD Housing Programs Final Rule,” (VAWA Final Rule, published November 16, 2016) with respect to the Public Housing and Housing Choice Voucher (HCV) programs (including the Project-Based Voucher (PBV)), and Section 8 Moderate Rehabilitation (Mode Rehab).

Overall, the VAWA Final Rule provides expanded housing protections for survivors of violence and fully codifies the provisions of the Violence Against Women Reauthorization Act of 2013 (VAWA 2013) into HUD’s regulations. At its core, VAWA 2013 prohibits housing providers from denying or terminating housing assistance on the basis that an applicant or tenant is a survivor of violence.

Notice PIH-2017-08 provides a summary of the major changes of the final rule’s impact on PIH programs and details who is eligible to receive VAWA protections and how eligibility is determined and certified.

Among its topics, the notice reviews policies for:

  • PHA Documentation Requirements
  • Notice of Occupancy Rights
  • Victim Confidentiality
  • Emergency Transfers (Emergency Transfer Plans must be in place by June 14, 2017)
  • Family Break-up
  • Record Keeping and Reporting Requirements
  • Developing Partnerships with Victim Service Providers
  • Lease Bifurcations
  • Establishing Waiting List Preferences
  • Landownership: Move with Continued Tenant-Based Assistance
  • Owners in the HCV Program
  • Assistance Under More Than One Covered Housing Program
  • Fair Housing and Nondiscrimination

Please note that this guidance does not encompass every aspect of the VAWA Final Rule and should be used in conjunction with the VAWA Final Rule. NAHRO will provide a deeper analysis of this PIH notice for members in a forthcoming edition of the NAHRO Monitor.

NAHRO attends meeting at HUD on the HCV Program

On May 10, NAHRO staff, along with other industry and advocacy groups, attended a meeting at HUD at which the current state of the Housing Choice Voucher (HCV) Program was discussed. HUD staff at the meeting had two main points for the attendees:

  1. With the passage of the FY 2017 budget, most PHAs will be receiving a similar amount or more in HAP than they received the year before (this is happening despite the 97.277 proration of HAP because of higher inflation factors);
  2. HUD highly recommends using their HCV forecasting tool.

Read more by clicking the link.

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HUD Releases Notice on Reducing Regulation and Controlling Regulatory Cost

On May 15, HUD published a notice and request for comment titled “Reducing Regulatory Burden; Enforcing the Regulatory Reform Agenda Under Executive Order 13777.” Comments can be made at Regulations.gov until June 14, 2017.

Executive Order 13771, issued January 30, requires that for every new regulation issued, at least two prior regulations be identified for elimination. The Order attempts to alleviate the costs associated with the government imposition of private expenditures, which must comply with Federal Regulations. Furthermore, to ensure cost efficiency, another Executive Order, 13777, signed on February, 24, requires HUD to establish a Task Force to evaluate its regulations’ effectiveness. The Order requires federal agencies, including HUD, to alleviate unnecessary regulatory burdens placed on the American people.

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