Starting in 2020, HUD is requiring that all PHAs have their Data Universal Numbering System (DUNS) numbers and Tax Identification Numbers (TIN) in active registration status in the System of Award Management (SAM) in order to receive funding. PHAs should check to ensure that their DUNS and TIN are active in SAM and that their SAM registration has not lapsed or expired. PHAs will not receive funding where TIN data conflicts in eLOCCS. More specifically, if the DUNS Organization TIN and Contractual Organizational TIN in LOCCS are inconsistent, PHAs will not receive funding.
HUD has already obligated funds to PHAs through mid-March. HUD will begin requiring active registration in SAM for DUNS and TIN for the next round of obligations. If a project is not funded because it does not comply with the above requirements, the agency should work to immediately update their registration in SAM or work to correct the inconsistency in TIN data in LOCCS. Once the SAM or TIN deficiency is corrected, the project will be funded in the next obligation.
Additional information about SAM and DUNS and TIN registration is available on the FMD website
PHAs can check their SAM status on the SAM website.
According to HUD there are currently 56 PHAs with expired SAM registrations. 37 PHAs have TIN mismatches. HUD will be providing a listserv reminder to all PHAs detailing the SAM and TIN requirements as well as the impact of noncompliance. In addition, HUD will send an email notification to PHAs in noncompliance, notifying them of their status and providing guidance on how to bring themselves into compliance.
In instances where the TIN data in LOCCS conflicts, the PHA should work with HUD’s CFO by sending an email to FWAC-SF1199A@hud.gov. The email subject should read “LOCCS TIN Correction to match SAM” and the email should include:
- A scanned copy of an IRS letter or other documentation that show the TIN in SAMS;
- A screen shot from SAM that show the TIN and DUNS
On December 26, HUD posted in the Federal Register a 60-Day Notice of Proposed Information Collection on a new Project-Based Voucher (PBV) Online Form. Through this new collection, HUD will require the submission of project-level data on all PBVs from PHAs. In doing this, HUD aims to better understand the existing number of units in PBV projects, what exceptions apply to these units, their rents, terms of contract, and numerous other potential data points. Comments are due February 24, 2020.
On December 19, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued final regulations implementing the Opportunity Zones tax incentive. Established by the Tax Cuts and Jobs Act of 2017, Opportunity Zones are a new community development program that encourages long-term investments in low-income urban and rural communities. The Opportunity Zone Program provides tax incentives for investors to re-invest unrealized capital gains into Qualified Opportunity Funds (QOF). QOFs are private sector investment vehicles that invest at least 90 percent of their capital in Opportunity Zones. NAHRO previously submitted comments to the IRS on Opportunity Zones in December 2018 and July 2019, and to the Department of Housing and Urban Development (HUD) in June 2019. The final Opportunity Zone regulations aim to provide clarity and certainty for investors and communities that make use of the tax incentive.
On December 16, HUD issued Notice PIH 2019-26. The Notice rescinds a prior notice (Notice PIH 2011-33) that provided guidance on the use of work preferences in public housing wait lists. Although the prior notice has been rescinded, agencies are still permitted to use work preferences as a local preference in their wait list if they so choose. NAHRO will continue to provide additional information on HUD notices and guidance in the future.
The Vera Institute of Justice (Vera) is soliciting applications from PHAs that would like to plan and implement reentry programs or change their policies toward people with conviction histories. Applications are due February 28, 2020.
The goals of the initiative are the following (quoted from Vera):
- increase housing access for people with conviction histories and increase public safety in communities that people return to on release from jails and prisons;
- improve the safety of public housing and surrounding communities through the use of reentry housing strategies; and
- promote collaboration among public housing authorities, law enforcement agencies, and other criminal justice stakeholders to effectively reduce crime and improve reentry outcomes for people leaving prisons and jails.
Vera encourages PHAs of all sizes–including those with Housing Choice Voucher (HCV) programs–to apply. Applicants must submit a letter of intent, an application narrative, and letters of support. While PHAs will first be informed, Vera will make a public announcement in April.
Additional information can be found here.
Tomorrow, HUD will publish in the Federal Register, fiscal year (FY) 2020 Annual Adjustment Factors (AAFs). These factors are used by certain Section 8 contracts to provide annual adjustments to monthly rents. These factors are used “to adjust contract rents for units assisted in certain Section 8 housing assistance payment programs during the initial (i.e., pre-renewal) term of the [Housing Assistance Payment] HAP contract.”
Section 8 programs that use AAFs include the Section 8 New Construction program, Substantial Rehabilitation program, the Moderate Rehabilitation program, and the Section 8 Loan Management and Property Disposition programs. Each program uses the AAFs differently.
These AAFs are distinct from Renewal Funding Inflation Factors (RFIFs), which are inflation factors used by the Housing Choice Voucher program and Operating Cost Adjustment Factors (OCAFs), which are used as inflation factors for other Section 8 contracts.
The pre-publication copy of the notice can be found here.
Yesterday, HUD held a landlord symposium in Indianapolis, Indiana. The Department recorded the sessions and will be making both the recordings and slides available soon. Until then, here is information from two slides from a presentation by a HUD official that I thought may be immediately useful.
5 Things PHAs Can Do to Improve Landlord Participation
- Single point of contact for landlords with quick response (landlord liaison)
- Enhanced communications from inspections team
- Damage claim funds reduce perceived risk of accepting an HCV tenant
- Direct deposit to ensure timely payment
- PHA organized engagement events for landlords to help landlords feel heard and valued
Low Resource Investment, High Impact
- Biennial Inspections – Take advantage of reduced inspections already authorized under
HOTMA [12/18/2019 edit – The Department of Housing and Urban Development Appropriations Act, 2014; see PIH 2016-05, Attachment K.]
- Landlord only phone days – Improve communication and response time by allocating staff time exclusively to manage landlord phone calls and emails one day per week
- Damage claim funds – establish damage claim fund to help landlords feel comfortable renting to HCV tenants
- Landlord relations working group – establish a working group with PHAs in your area to strive for consistency in PHA policies and practices that impact landlords