Summary of CARES Act Waivers Exploratory Meeting

The following is a summary of an exploratory meeting with HUD staff on 5/19/21 on CARES Act statutory waivers, considering the potential advantages and disadvantages of making each waiver permanent. PHAs and industry group members in attendance offered feedback and comments about their experience with the waivers, to give context to the operation of each waiver in practice. NAHRO will continue to be engaged in discussions to ensure efficient and effective HUD affordable housing programs that serve the needs of local communities. Select comments, questions, and concerns from the meeting are included below:

  1. HQS Inspection Requirement: Biennial Inspections
  • Allows for delay in biennial inspections
  • PHAs must require landlord certification there are no life-threatening deficiencies
  • All delayed biennial inspections must resume by 6/30/21 and be completed by 12/31/21

Comments on how to assure units meet HQS standards:

Switch to random inspections

For new units for last 2 years, allow landlord to do self-inspection but tenant has to sign-off on no life-threatening issues, and then every 5th unit look out for 90 days

RVI  was initially not well-received by households or inspectors, but now successful as inspectors became efficient with technology and residents got familiar with the process

2. Public Housing Agency Annual Self-Inspection

  • Waives the requirement that the PHA must inspect each project


Goal to ensure compliance without being intrusive

Flexibility of the waiver is good, but residents need a mechanism to complain to the PHA

One solution is to send property staff with LIHTC state inspections, which are unofficial but reduce intrusions and get eyes on the property

3. Homeownership Option: Initial HQS Inspection

  • Waives the requirement to perform an initial HQS inspection to begin making homeownership assistance payments
  • Requires family to obtain independent professional inspection

4. Family Unification Program (FUP): FUP Youth Age Eligibility to Enter HAP Contract

  • Allows PHAs to increase age to 26 for foster youth to initial lease up


Multiple comments that expanding age would help program with utilization, and benefit program overall

Youth considered a dependency on parental health insurance until 26 if parents have health insurance, and would help with youth in more expensive cities

Questions about different timelines for youth in FSS for FYI and FUP

5. Community Service and Self-Sufficiency Requirement (CSSR)

  • Temporarily suspends CSSR


Has no specific outcome

Administrative argument to made as well that it takes unnecessary time, effort, funding to manage

6. 1-and 2-Year Substantial  Improvement Requirements

  • For PHAs designated as troubled prior to the date of this Notice that have not received a PHAs assessment for the first full fiscal year after the initial notice of the troubled designation.
  • HUD will: (1) evaluate the 1-year substantial improvement benchmark based on the first released score for fiscal years ending on or after June, 30, 2022; and (2) toll the evaluation of the 2-year recovery benchmark to the next sequential fiscal year.

7. Extension of Deadline for Programmatic Obligation and Expenditure of Capital Funds

  • Provides an 18-month extension for obligation and spending of cap funds


Construction currently very difficult because of high building costs, can only get materials costs 6 weeks at a time

Hard to make a 5-year plan when we don’t know what the funding will be

Additional waivers and comments:

  • Waiver for publishing openings and closing of wait lists:
    • Feedback: Expensive to publish in print, requests to consider alternative methods of publication

Sec. Fudge Testifies on Importance of the American Jobs Plan

HUD Secretary Marcia Fudge and Department of Transportation Secretary Pete Buttigieg testified this morning in a joint hearing on the American Jobs Plan for the Senate Committee on Banking, Housing, and Urban Affairs. Titled “21st Century Communities: Expanding Opportunity Through Infrastructure Investments,” the joint hearing focused on how housing and transit work together to support communities and jobs, and the importance of housing as infrastructure.

In her testimony, Sec. Fudge focused on the ways that “yesterday’s lack of investment” is driving the affordable housing crisis through lack of supply of housing units and state of disrepair of existing housing units. She emphasized the different ways the American Jobs Plan (AJP) addresses these two issues, which includes $213 million to build 2 million new homes and $40 billion to repair existing public housing infrastructure.

In his testimony, Sec. Buttigieg highlighted how the relationship between housing and transit infrastructure impacts families who must choose between “living impossibly far from work to afford housing,” relying on aging transit systems in need of repair, or “paying more for housing than they can afford in order to have a reasonable commute.”  

Both Sen. Tim Scott (R-SC) and Sen. Kyrsten Sinema (D-AZ) separately asked about manufactured housing, and the potential for HUD to issue guidance on manufactured housing. Sen. Scott emphasized the importance of manufactured housing in disaster recovery his state, and Sen. Sinema focused on the importance of manufactured housing considering increased construction materials costs. Sec. Fudge said HUD had been preoccupied by COVID, but supports manufactured housing as resilient, energy efficient, and affordable, and should have guidance out by the end of the year.

Sen. Bob Menendez (D-NJ) asked about the lack of available senior housing, and how that might be a growing problem as the number of aging Americans significantly increases in the next decade. Sec. Fudge responded that many people forget a large percentage of public housing residents are seniors and need to be able to age in place, and that requires investing in Section 202.

Several senators also asked about landlord and community incentives to lease to voucher holders or to build new housing. Sen. Kevin Cramer (R-ND) took the hearing as an opportunity to talk about his new bill with Sen. Chris Coons (D-DE).  Sen. Elizabeth Warren (D-MA) asked about how the AJP currently addresses zoning, and how more targeted incentives could motivate local communities to address exclusionary zoning, bans on multifamily construction, and other barriers to more affordable housing.

You can watch the hearing here.

You can find the testimony of the witnesses here.

FCC Launches Temporary Emergency Broadband Benefit Program

As of May 12, recipients of Federal Public Housing Assistance and other qualifying households can apply for the temporary Emergency Broadband Benefit Program (EBBP) to receive a monthly discount on internet access, as well as a one-time discount on equipment. The Federal Communication Program (FCC) program offers $50/month off of broadband service, $75/month off of broadband service on Tribal land, and a one-time discount of $100 for a laptop, tablet, or desktop, as long as consumers pay between $10-$50. The program pays internet service providers directly, sending discounted bills to participants.

Recipients of Federal Public Housing Assistance are eligible, as are families with income at or below 135% of federal poverty guidelines. Households also qualify if any member of the household:

  • Qualifies for Lifeline. Recipients of Lifeline qualify automatically, and can receive both benefits simultaneously.
  • Participates in Supplemental Nutrition Insurance Program (SNAP), Medicaid, Supplemental Security Income (SSI), Veterans Pension and Survivor Benefits.
  • Participates in Tribal programs (Tribal Head Start, Tribal TANF, or Food Distribution Program on Indian Reservations).
  • Receives Free or Reduced-Price Lunch in 2019-2020 or 2020-2021 school year, or received a Pell Grant in the current year.
  • Experienced a substantial loss of income after February 29,2020. Total household income must be no more than $99,000 for single tax filers, and $198,000 for joint tax filers.
  • Already participates in a low-income or COVID-19 program with their internet service provider.

The EBBP limits families to one monthly broadband discount and one device discount per household, defined as people living together who also share money. This is a temporary program, which will end either when funding is exhausted or six months after the Department of Health of Human Services (HHS) announces the end of the COVID-19 emergency.

To apply, see more here.

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HUD, HHS Partner on COVID-19 Vaccine Program

The U.S. Departments of Housing and Urban Development (HUD) and Health and Human Services (HHS) have partnered to create a new program to make COVID-19 vaccines and testing more accessible for HUD-assisted households and people experiencing homelessness. Under the program, funded by the American Rescue Plan, HUD and HHS are directing all community health centers to build on or create new partnerships with HUD participants (including PHAs, Continuums of Care, and homeless providers) to facilitate on-site testing and vaccine clinics at HUD-assisted sites and to create mobile facilities to reach those experiencing unsheltered homelessness. HUD and HHS will support these partnerships by tracking the number of people being vaccinated and the number of vaccine clinics, as well as leveraging a new mapping tool to identify high-need areas for vaccination. Vaccines will come from the Health Center COVID-19 Program, which sends vaccines directly to 800 health centers across the country.

In addition to the vaccine sites themselves, these programs will also help with registering and scheduling testing and vaccine appointments, conduct outreach on vaccine safety and efficacy, and provide transportation to vaccination for those with limited mobility. Beyond COVID-19, the program should also provide information on access for more comprehensive primary health care services for participants. HUD and HHS estimate this will reach approximately 6,000 multifamily housing properties, 6,700 homeless shelters, and 7,500 public housing properties.   

More information can be found here.