The COVID-19 pandemic has adversely impacted many PHAs’ voucher operations. In recognition of this, HUD has afforded PHAs that meet certain criteria the opportunity to waive their Section 8 Management Assessment Program (SEMAP) scores in recognition of the pandemic environment. There are also certain other instances when PHAs may not receive a SEMAP score. This blog post illustrates three instances where a PHA may not receive a SEMAP score.
Instances Where a Prior SEMAP Score Is Carried Forward
PHAs with a fiscal year end (FYE) on Dec. 31, 2021 will have their most recent SEMAP score on record carried forward. See pages 39 and 40 of Notice PIH 2021-14 (HA). (Note: For these PHAs, they will not qualify for the expedited waiver described below for their FYE on Dec. 31, 2022.)
PHAs that Receive an Expedited SEMAP Waiver
PHAs with a FYE of 3/31/22, 6/30/22 or 9/30/22 may request to waive the application of SEMAP in its entirety, but only if the PHA has SEMAP indicators that were–directly or indirectly–affected because of a disruption to PHA operations caused by the PHA’s adoption of CARES Act waivers. See page 4 of Notice PIH 2021-34. Additional information on applying for the SEMAP waiver or other expedited waivers can be found in Notice PIH 2021-34. The deadline to apply for expedited waivers has been extended to April 1, 2022. After April 1, PHAs may still apply for a regulatory waiver, but the expedited waiver process will no longer be available. See Notice PIH 2022-04.
Certain Small PHAs (Fewer than 250 Assisted Units)
HUD’s regulations state that HUD will assess and score SEMAP for PHAs with fewer than 250 assisted units every other PHA fiscal year unless the PHA elects to have itself scored annually or the PHA is troubled. 24 CFR 982.105(a)(2). Clarifying HUD guidance states that non-troubled PHAs with fewer than than 250 assisted units and FYEs of 3/31/2022 or 6/30/2022 do not have to have submit a SEMAP certification. See chart and accompanying text on page 3 of the IMS-PIC SEMAP Sub Module PHA Certification and PHA Appeal Submission Instructions, March 2019.
PHAs that fall into one of these categories may not receive an SEMAP score from HUD.