HUD Releases Notice on Executive Compensation for 2017

HUD recently issued Notice PIH-2018-13 providing additional information on calendar year (CY) 2017 executive compensation reporting. The Notice specifically instructs PHAs on how to use the HUD-52725 Form that reports executive compensation for CY 2017. The requirements apply to all PHAs that administer a public housing or Section 8 program, including PHAs that have  converted their entire public housing portfolio through RAD that still receive funding sourced from Section 8 or 9 of the US Housing Act of 1937.
The FY 2017 Consolidated Appropriations Act included language (members only) prohibiting PHAs from using any Tenant-Based Voucher, Operating Fund, or Capital Fund dollars to pay any amount of salary above the base rate of pay for level IV of the Executive Schedule, or $161,900 for FY 2017. This restriction included salary as well as bonuses or other incentive pay. This provision affirmed a policy that has been in place since the FY 2015 Consolidated Appropriations Act.

PHAs must report compensation for the top management official, the top financial official, and the highest compensated employee who is neither the top management official nor the top financial official. PHAs must submit their CY 2017 executive compensation data to HUD using form HUD-52725. HUD-52725 is a web-based form PHAs submit online through HUD’s Secure Systems portal.
HUD has noted in the guidance that any PHA that fails to comply with the PHA
executive compensation reporting requirements will be in violation of the PHA’s Annual Contributions Contract (ACC). HUD recently issued an amended Annual Contributions Contract (ACC) (members only) that PHAs automatically agreed to once they drew down FY 2018 Capital Fund Program (CFP) grants. This amended ACC includes specific language requiring adherence to the law established by the FY 2015 Appropriations Act that capped salaries for certain PHA officials. NAHRO has concerns regarding HUD’s implementation process for this amended ACC as well as the substantive changes included within the amended ACC.

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