NAHRO Submits Regulatory Reform Comments to HUD

On June 14, NAHRO submitted its comment letter to HUD’s request for comment on Reducing Regulatory Burden; Enforcing the Regulatory Reform Agenda Under Executive Order 13777.

NAHRO identified many regulations that would make good candidates for streamlining. Each of the regulations met at least one of the following reasons for streamlining:

(a) The regulation results “in the elimination of jobs, or inhibits job creation”;

(b) The regulation is “outdated, unnecessary, or ineffective”;

(c) The regulation imposes “costs that exceed benefits”; or

(d) The regulation creates a “serious inconsistency or otherwise interferes with regulatory reform initiatives and policies.”

The regulations listed are non-exhaustive. NAHRO’s comment letter is a start of a conversation between the Department and NAHRO. Given the limited time to compile this list, NAHRO expects to identify additional avenues for further regulatory streamlining, which we will share with the HUD.

NAHRO’s comment letter is organized into three sections: Public Housing and Section 8 recommendations; Community Planning and Development; and recommendations on cross-cutting programs and initiatives. Within each major section are topic headers with NAHRO’s recommendation on each topic.

NAHRO, CAP Offer Free Webinar on PHA-CAA Partnerships

Does your Public Housing Authority (PHA) want to provide necessary non-housing services to your residents, such as access to case management, transportation services, food security, or the Low-Income Home Energy Assistance Program (LIHEAP)? Is your Community Action Agency (CAA) looking for better ways to partner with your local PHA to help your clients find safe, secure, affordable housing? If so, please join the National Association of Housing and Redevelopment Officials (NAHRO) and the Community Action Partnership (CAP) for a free webinar to learn about how PHAs and CAAs work hand-in-hand to help address poverty in communities across the nation.

On June 20, from 1:30-3:00 p.m. EDT, NAHRO Senior Director of Congressional Relations John Bohm, CAP CEO Denise Harlow, and NAHRO and CAP staff will discuss the results of a recent survey conducted by NAHRO and CAP, provide examples of established working relationships between PHAs and CAAs, and examine the results achieved by these partnerships.

Nationally, PHAs help over 4.8 million families and individuals by providing safe, decent, affordable housing for families in need. Community Action Agencies provide critical programs to more than 15 million people with low incomes every year. Collaboration increases the capacity of both PHAs and CAAs, and making the CAA programs and services available to public housing residents puts communities are in a far better position to combat poverty. Join us for this free webinar to learn how to build and strengthen these collaborations.

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FY 2018 Proposed Budget: Process and In-Depth Analysis

The Administration’s budget proposal, released on May 23, is the first step in a months-long journey. Now that the Administration has released its recommendations, this Direct News will provide in-depth coverage of how it would affect the Community Development, Section 8 and Public Housing programs administered by HUD.

The budget proposal requests cuts, which if implemented, would be devastating for communities. NAHRO strongly opposes the President’s budget proposal and will work to provide necessary and responsible funding for critical housing and community development programs. NAHRO will also fight for long-overdue program and regulatory reforms that can reduce costly administrative burdens.

Members should note that the President’s request is the beginning and not the end of the budget and appropriations process. The Administration’s budget request has over the years become a political document that reflects the fiscal goals and priorities of the Administration for the upcoming fiscal year. It does not carry the force of law. Congress, who controls the nation’s purse strings, can choose to accept the request wholesale, pick and choose parts of it, or reject it outright, which they frequently do. NAHRO will fight to ensure that work undertaken by our members to address critical housing needs for vulnerable families can be sustained.

NAHRO’s initial review can be found in The NAHRO Blog’s post, “President Officially Releases FY 18 Budget Proposal, Slashes Housing and CD Spending.” NAHRO members click on the links below to review the in-depth FY 2018 budget request analysis for Community Development, Section 8, and Public Housing:

Community Development (NAHRO Login Required)

Section 8 (NAHRO Login Required)

Public Housing (NAHRO Login Required)

President Officially Releases FY 18 Budget Proposal, Slashes Housing and CD Spending

The President’s FY 2018 budget request was officially released today.

The proposal, which largely mirrors the budget preview released in March makes steep cuts to housing and community development programs, slashing the overall HUD budget by $6 billion. The bulk of the cuts are to community development programs, which are largely eliminated. The budget also cuts the Public Housing Capital Fund by 68 percent, requesting a funding level of just $628 million for the upcoming fiscal year. The budget document also mentions that the Administration is working toward a “comprehensive package of rental assistance reforms” including “increased tenant rent contributions, the establishment of mandatory minimum rents, and the end of utility allowance reimbursements, among others.”

These proposed cuts, if implemented, would be devastating for communities. NAHRO strongly opposes the President’s budget proposal and will work to provide necessary and responsible funding for critical housing and community development programs. NAHRO will also fight for long-overdue program and regulatory reforms that can reduce costly administrative burdens. Listed below are the Administration’s proposed 2018 funding levels for programs central to the work of NAHRO’s membership.

  • Public Housing Operating Fund: $3.9 billion, $500 million less than FY 2017
  • Public Housing Capital Fund: $628 million, $1.31 billion less than FY 2017
  • Choice Neighborhoods: $0, $137.5 million less than FY 2017
  • Tenant-Based Rental Assistance: $19.318 billion, $974 million less than FY 2017
  • Section 8 Housing Assistance Payment Renewals: $17.584 billion, $771 million less than FY 2017
  • Ongoing Administrative Fees: $1.54 billion, $100 million less than FY 2017
  • Family Self-Sufficiency: $75 million, level funding from FY 2017
  • Section 8 Project-Based Rental Assistance: $10.751 billion, $65 million less than FY 2017
  • Community Development Block Grant: $0, $3 billion less than FY 2017
  • HOME Investment Partnerships Program: $0, $950 million less than FY 2017
  • Housing Opportunities for Persons with AIDS: $330 million, $26 million less than FY 2017
  • Homeless Assistance Grants: $2.25 billion, $133 million less than FY 2017
  • National Housing Trust Fund: $0, approximately $219 million less than FY 2017

Members should note that the President’s request is the first step in the budget and appropriations process. The Administration’s budget request has over the years become a political document that reflects the fiscal goals and priorities of the Administration for the upcoming fiscal year. It does not carry the force of law. Congress, who controls the nation’s purse strings, can choose to accept the request wholesale, pick and choose parts of it, or reject it outright, which they frequently do.

Though the budget preview released in March was largely rejected by members of Congress, it is still important to communicate to your members of Congress the impact these types of cuts would have in your community.

This year’s budget comes months later than the traditional budget release date of the first Monday in February, placing a serious time constraint on Congress to approve as many appropriations bills as possible prior to leaving Washington for the August recess. Typically, by this time in the year, cabinet agency funding bills for 2018 would have already been approved. For example, the Senate passed the FY 2017 Transportation, Housing, and Urban Development (T-HUD) spending bill on May 19, 2016. Because of this shortened timeline, it is largely expected that a continuing resolution (CR) will be necessary to keep the government functioning beyond the end of the fiscal year on September 30.

Detailed coverage of the 2018 HUD budget request will follow later this week, which will give the membership more specific information and analysis that will assist you in educating and inform decision-makers and other interested parties.

VAWA Implementation e-Briefing Next Week

VAWA 2013 Implementation
A NAHRO Professional Development e-Briefing

Next Tuesday, May 16, 2017, 1:30 – 3:00 pm EDT

Last November, HUD published a long-awaited final rule that provides expanded housing protections for survivors of violence by fully codifying the provisions of the Violence Against Women Reauthorization Act of 2013 (VAWA 2013) into HUD regulations. At its core, VAWA 2013 prohibits HUD housing providers from denying or terminating housing assistance on the basis that an applicant or tenant is a survivor of violence.

Join NAHRO’s in-house policy experts as they discuss compliance with the final rule and the requirements for completing an emergency transfer plan and providing emergency transfers. HUD’s deadline to implement a VAWA Emergency Transfer Plan is June 14, 2017.

Just $95 for NAHRO Members!

Reminder: Whether you’re watching alone or with an audience of 100, only one registration per connected device is required, making NAHRO Professional Development’s e-Briefings an outstanding value!

Online registration will close Monday, May 15 at 11:59 pm EDT.

President Signs FY 2017 HUD Spending Bill

After seven months and three continuing resolutions, Congress on Thursday finally approved, and the President on Friday signed, an omnibus spending bill of all 11 remaining appropriations bills, including Transportation, Housing and Urban Development.

The $1.07 trillion deal provides funding for federal departments and agencies until the end of the fiscal year on September 30, 2017. The bill contains level funding or a slight increase to most housing and community development programs, with few exceptions.

The bill was passed on a bipartisan basis easily in both the House and the Senate. On Wednesday, the House approved the bill by 309 to 118 and on Thursday the Senate approved it by 79-18, sending the omnibus to the President for his signature. President Trump signed the bill this afternoon.

The final passage of the omnibus ends more than seven months of delays in finalizing spending for the current fiscal year. Initially opting to postpone making final spending decisions until after the election, Congress approved a short-term spending bill that ran out in mid-December, with the intention of wrapping up work on the fiscal year during the lame duck. However, the then President-elect signaled to Congress that he would like to have input on spending in the current fiscal year, so legislators passed a short-term bill until April 28. Congressional leadership, close to wrapping up negotiations, signaled last week that they needed an additional week of time, requiring the passage of yet another week-long continuing resolution.

The path to a deal was bumpy, but far less rocky than it could have been. Controversial policy riders and requests from the President to fund a border wall with Mexico and an increase defense spending were omitted, likely delaying a larger battle for later in the year. Critically, the parity between defense and non-defense spending was also maintained, a huge victory in a difficult political environment.

NAHRO Acting CEO John Bohm called upon Congress to begin work immediately on a responsible 2018 federal spending bill and expressed concern regarding the year-over-year need to approve continuing resolutions. “Despite promises to return to regular order with regard to the appropriations process,” Bohm said, “NAHRO members continue to struggle to meet local needs given the uncertainties and delays inherent in the approval of continuing resolutions. With the 2018 fiscal year to begin in a mere four months (including the annual August recess) there is at this point every assurance that we will be operating under yet another CR come October. We can do better than this to help those in need.”

Below is a summary of the FY 2017 housing and community development funding levels. The NAHRO Policy Staff has conducted a detailed analysis of the Public Housing, Section 8 and Community Development provisions and funding levels. NAHRO Members can read each of these deep-dive analysis documents on the NAHRO website:


Housing and Community Development Funding Levels

  • Public Housing Programs
    • Public Housing Capital Fund – $1.9415 billion, $41.5 million higher than FY 2016
      • Competitive Lead-Based Paint Grants – $25 million, new program
      • ROSS – $35 million, level funding
      • Emergency Capital Needs – $21.5 million, $500,000 less than FY 2016
      • Jobs Plus – $15 million, level funding
      • PH Financial Physical Assessment – $10 million, $7 million higher than FY 2016
    • Public Housing Operating Fund – $4.4 billion, $100 million less than FY 2016
    • Choice Neighborhoods Initiative – $137.5 million, $12.5 million higher than FY 2016
    • Family Self-Sufficiency – $75 million, level funding
    • RAD – expanded to 225,000 units
  • Section 8 Programs
    • Tenant-Based Rental Assistance – $20.292 billion
      • Section 8 Housing Assistance Payment Renewals – $18.355 billion, $663 million higher than FY 2016
      • Ongoing Administrative Fees – $1.64 billion, level funding
    • Section 8 Project-Based Rental Assistance – $10.816 billion, $196 million higher than FY 2016
  • Community Development Programs
    • Community Development Block Grant – $3 billion, level funding
    • HOME Investment Partnerships – $950 million, level funding
    • Housing Opportunities for Persons with AIDS – $356 million, $21 million higher than FY 2016
    • Homeless Assistance Grants – $2.383 billion, $133 million higher than FY 2016

MTW Operations Notice Comment Period Reopens

In today’s Federal Register Public Inspection Documents, HUD included, “Operations Notice for the Expansion of the Moving to Work Demonstration Program Solicitation of Comment; Waiver Revision and Reopening of Comment Period.” It is anticipated that this notice will be published in the Federal Register tomorrow, May 4, 2017.

This notice reopens, for 30 days from its publication in the Federal Register, the comment period of the January 23, 2017 Moving to Work (MTW) Operations Notice. This notice also makes revisions to one General Waiver in Appendix 1 and two Conditional Waivers in Appendix 2.

The General Waiver that is revised focuses on the Family Self-Sufficiency (FSS) program and the updated waiver allows housing agencies to require participation in an FSS program. If an agency makes FSS participation mandatory, the agency must also have and apply exceptions and hardship provisions.

The two Conditional Waivers that are revised focus on Work Requirements for Public Housing (PH), and Housing Choice Voucher (HCV) and Project-Based Voucher (PBV) residents. The first waiver is for “PH — Work Requirements” and the second is for “HCV & PBV — Work Requirements” but the revision is the same – the housing agency may implement work requirements for PH, HCV, and PBV residents between the ages of 18 and 61. The previous versions of these waiver listed 54 as the maximum age.

NAHRO will continue to engage with HUD and housing agencies to maximize the regulatory relief and flexibility essential to the MTW program and the MTW expansion.

FY2017 Omnibus Spending Bill Agreement

On Monday, May 1st, an agreed to fiscal year 2017 omnibus appropriations bill was released. The spending deal would fund the Federal government through September 30, 2017. This omnibus must still be voted on in the House and Senate and then be signed by the President but there is optimism and agreement among the parties involved.

The omnibus provides the Department of Housing and Urban Development (HUD) with $38.8 billion for fiscal year 2017, which is a 1 percent increase over fiscal year 2016 levels. Below is a brief breakdown of a few of the HUD program areas. The NAHRO Policy Team will continue to analyze the omnibus and will provide a deep dive analysis once the omnibus becomes law.

Public Housing (PH)

The omnibus funds the PH Operating Fund at $4.4 billion, which is $100 million less than fiscal year 2016.

The PH Capital Fund is funded at $1.9415 billion, an increase of $41.5 million from fiscal year 2016. This capital funding includes set-asides of $35 million for Resident Opportunities and Self-Sufficiency (ROSS), $25 million for new Competitive Lead-Based Paint Hazard Grants, $21.5 million for Emergency Capital Needs, $15 million for Jobs Plus Pilot, and $10 million for PH Financial and Physical Assessment Activities.

Section 8

Tenant-Based Rental Assistance is funded in the omnibus at $20.292 billion, which is an increase of $663 million more than fiscal year 2016. This amount includes set-asides for Section 8 Housing Assistance Payment Renewals funded at $18.355 billion, Ongoing Administrative Fees at $1.640 billion, Special and Ongoing Administrative Fees at $10 million, Tenant Protection Vouchers at $110 million, and new Incremental Vouchers at $57 million. The Mobility Demonstration program is not funded in the FY2017 omnibus appropriation bill.

Community Development

The Community Development Block Grant (CDBG) and the HOME Investments Partnerships Program (HOME) have flat funding at $3 billion and $950 million respectively.

The Housing Opportunities for Persons with AIDS (HOPWA) is funded at $356 million, an increase of $21 million from FY2016 and the Homeless Assistance Grants are funded at $2.383 billion, an increase of $133 million over FY2016 levels.

Other Rental and Service Programs

The Family Self-Sufficiency (FSS) program is funded at the same level as FY2016, $75 million.

Section 8 Project-Based Rental Assistance increased $196 million from FY 2016 levels to $10.816 billion.

The Rental Assistance Demonstration (RAD) program did not receive any additional funding but the cap on the number of units eligible for the program was increased from 185,000 to 225,000 and the RAD program was extended from 2018 to 2020.

The Neighborhood Reinvestment Corporation (NeighborWorks) was funded at $140 million with $5 million to be used for a multi-family rental housing program.

The United States Interagency Council on Homelessness is funded at $3.6 million and is extended to October 1, 2018.

Affordable Housing Accreditation Board Looking for Input on Standards and Guidelines

The Affordable Housing Accreditation Board (AHAB) is an independent, non-profit organization with the mission to establish a comprehensive accreditation system that recognizes excellent governance, quality management, and best practices in affordable housing programs.

AHAB’s accreditation standards and evaluation methods are designed to cover a wide range of affordable-housing provider types in order to increase the likelihood that the provider’s mission, structure, financial resources, and leadership will result in delivering quality, affordable housing and services to residents within their communities.

In 2012, AHAB began developing, with feedback from our colleagues, an accreditation system for the affordable housing industry that recognizes good management, quality programs, and best practices. AHAB believes the Accreditation Standards and Guidelines serve as the framework for the indicators that will be used for the accreditation process.

AHAB has developed a survey tool to provide feedback on the Accreditation Standards and Guidelines. AHAB needs your critical eye to examine if these are an acceptable foundation for an excellent accreditation program. The Standards are divided into eight general areas with associated Guidelines. Conceptually, upon “go-live” there will be an application process, a comprehensive review of initial documentation, and a site visit by reviewers. The reviewers will utilize more specific Indicators that demonstrate successful achievement of the Standards and Guidelines.