On June 5, NAHRO submitted comments in response to HUD’s “Operations Notice for the Expansion of the Moving To Work Demonstration Program Solicitation of Comment; Waiver Revision and Reopening of Comment Period.” This notice reopened the comment period of the January 23, 2017 Moving to Work (MTW) Operations Notice for 30 days, and also made revisions to one General Waiver in Appendix 1 and two Conditional Waivers in Appendix 2. NAHRO also submitted in-depth comments to HUD on the Operations Notice in late March (members only).
NAHRO’s comment letter makes several suggestions over the course of three main sections. The first section responds to HUD’s specific request for comments on revisions to the Operations Notice included in the revised Notice, while the second section highlights some of NAHRO’s general recommendations to improve the Operations Notice. The third section, “Attachment 1,” contains NAHRO’s previously submitted comments to HUD regarding the MTW Expansion Operations Notice.
NAHRO’s general comments asked HUD to include “safe harbors” that PHAs could use for conditional waivers, to clarify the general purpose of the Operations Notice, to clarify the use of waivers not included in the Operations Notice, and to make specific changes to waivers listed in the Operations Notice.
NAHRO’s comment letter can be found here.