Author: Georgi Banna

NAHRO meets with HUD PIH Leadership

~ Georgi Banna ~ Leave a comment

Georgi John HUD 16-8-9

NAHRO’s Acting CEO, John Bohm, and the NAHRO Policy Team members; Georgi Banna, Eric Oberdorfer and Tushar Gurjal; along with PHADA and CLPHA met with HUD’s Public and Indian Housing Principal Deputy Assistant Secretary (PDAS), Lourdes Castro-Ramierz, and many of the PIH department leadership.

Among the topics discussed were the priorities for implementing the Housing Opportunities Through Modernization Act (HOTMA/HR 3700); upcoming HUD rules such as Smoke-Free Housing, Small Area Fair Market Rents (SAFMRs), HCV Administrative Fee Formula; Moving to Work (MTW) Expansion; and Triennial Recertifications; and the current priorities of NAHRO, PHADA, CLPHA and HUD. NAHRO and CLPHA were also thanked for their current and continued work in affordable housing and education and the improvement of educational outcomes for the children our members serve.

NAHRO is committed to keeping open and productive lines of communication and will continue to share the thoughts and concerns of our members with HUD.

HUD Seeks Comments on CoC Formula, Proposes Formula Alternatives

~ Georgi Banna

On July 25, the “Continuum of Care Program: Solicitation of Comment on Continuum of Care Formula” notice will be published by HUD in the Federal Register. The purpose of the notice to solicit comments on the current Continuum of Care (CoC) formula and a number of updated CoC Preliminary Pro Rata Need (PPRN formula) options. Comments will be due 60 days after the notice is issued – September 23, 2106, based on the anticipated Federal Register date of July 25.

The current PPRN formula was published by HUD as the interim rule on July 31, 2012, and is a combination of Emergency Solutions Grants (ESG) program grant funds and Community Development Block Grant (CBDG) funds awarding formulas. This notice proposes four alternative formulas that use various factors and factor weights.

HUD has made available two tools to explore potential updates to the PPRN formula. The first tool is the CoC PPRN Proposed Formula Impacts by CoC resource where users can learn more about the CoC-level PPRN funding impact of implementing each of the four proposed formulas in the Notice, as compared to the FY 15 PPRN amounts by CoC. The second tool, CoC PPRN Alternate Formula Testing Tool, tests the impact of potential factors for an alternate CoC PPRN formula.

Additional information will be available on NAHRO’s Community Development Resource Center and on HUD’s notice website.

HUD Revises Schedule for PHA Operating Subsidy Revisions

~ Georgi Banna

On July 20, HUD released an updated PIH Notice 2016-10 REV.1 “Public Housing Operating Subsidy Eligibility Calculations for Calendar Year 2016” that contains the 2016 Revision Schedule for the HUD-52723 (Opfund Subsidy) and HUD 52722 (UEL). The revised notice contains the revised schedule for the submission of PHA revisions. The time period for PHA submission of revisions has been extended for PHAs.

2016 Revisions Schedule:

Items: Finish lines:
PHA revisions due to FOs. 8/15/2016, COB Mon., Aug 15th
FOs due to FMD 8/29/2016, COB Mon., Aug. 29th
FMD publishes Final Eligibility Report 9/28/2016, COB Wed., Sept. 28th
Final Obligations before Nov. 1st 11/1/2016, COB Mon. Oct. 31

The revised PIH notice is available on the NAHRO Public Housing Resource Center (Login Required) and the HUD website.

Importance of Grade Level Reading, NAHRO Signs MOU

~ Georgi Banna

On Friday July 15, NAHRO and the Campaign for Grade-Level Reading (CGLR) signed a Memorandum of Understanding (MOU.) NAHRO and CGLR are committed to ensuring that children living the communities that NAHRO members serve are set up for success in schools — by arriving ready to learn, maintaining consistent attendance and gaining access to enrichment over the summer so they don’t fall behind.

An important predictor of school success and high school graduation is grade-level reading by the end of third grade. Currently 80 percent of children from low-income families are missing a milestone that is a major predictor of high school graduation and success in life — reading proficiency by the end of third grade.

NAHRO believes that schools need a 24/7/365 partner and understands that Public Housing Authorities (PHAs) and community development organizations are uniquely positioned to fill this role. Through our Housing and Education Task Force and our Housing America campaign, NAHRO raises national awareness of the need for and importance of safe, quality, affordable housing in addition to advocacy and ensuring that children receive the education they need and deserve. NAHRO shares the CGLR’s desire to help PHAs and community development organizations become learning enablers by ensuring that the young learners in affordable housing can read proficiently by the end of third grade and to promote grade-level reading as a step on the path to future success.

More information on the Campaign for Grade-Level Reading is available on their website – www.GradeLevelReading.net. Updates on this new and exciting NAHRO – CGLR partnership will be posted on this blog and the NAHRO website – www.nahro.org – over the coming weeks and months.

HR 3700 Sent to President for Signature

~ Georgi Banna

In a huge victory for NAHRO and its members, the Senate today approved the Housing Opportunity Through Modernization Act (HR 3700) unanimously by a voice vote, sending the bill to the President for his signature.
The bill was approved using a process known as “hot-lining”, a procedure to quickly pass non-controversial legislation. It was passed by the House unanimously on February 2, 2016.

“NAHRO commends the House and the Senate for their work on this critical legislation. With the President’s signature, housing authorities across the country will be able to do their jobs more efficiently and serve their residents and communities better,” said NAHRO President Steve Merritt.

NAHRO thanks everyone involved in the passage of this important legislation, including legislators and their staff, NAHRO membership, and partner housing advocacy groups.

“This is a big deal. The passage of HR 3700 marks the culmination of years of work by members of Congress and their staff, NAHRO members and staff, and the housing community at large. It demonstrates that housing reform is a priority and can be accomplished, and that the legislative process does still work,” said NAHRO’s Acting CEO John Bohm.

S. 3083 Introduced in Senate – Take Action Now!

~ Georgi Banna

Senate Banking, Housing and Urban Affairs committee members Tim Scott (R-S.C.), Robert Menendez (D-N.J.), along with Senators Roy Blunt (R-Mo.), and Christopher Coons (D-Del.) took a big step this week by introducing S. 3083, which is companion legislation to the House-passed H.R. 3700.  Substantially, the bills are the same.

This is a huge victory, but our work is just beginning in the Senate – contact your Senators today to urge them to take action immediately on S. 3083 – send a letter to your senators and tweet at them (your Senators’ Twitter handles can be found on their websites).

Sample tweets:

  • TY @RoyBlunt @SenatorTimScott @ChrisCoons @SenatorMenendez for #S3083 – I will help you pass this critical legislation @NAHRONational
  • #PHAs hit hard by budget cuts, over regulation – S 3083 protects residents, helps #PHAs serve comm better- @SENATOR pass #S3083
  • House passed #HR3700 unanimously 4 months ago. @SENATOR please act on #S3083

NAHRO has supported many of the reforms within the bill since it was originally drafted in the House; NAHRO President Steve Merritt testified at a hearing on H.R. 3700 in October 2015 and NAHRO has been working with a coalition of housing stakeholders pushing for the passage of the bill. In April, NAHRO joined the coalition on a letter to Senators urging the quick passage of the legislation.

Specifically, NAHRO supports these provisions of HOTMA (H.R. 3700 and S. 3083):

  • Capital Replacement Reserves – Using NAHRO language also included in the Senate FY16  and FY17 Appropriations Acts, HOTMA would allow PHAs to voluntarily establish Capital Fund replacement reserves.
  • Subsidy Flexibility – HOTMA would allow for PHAs to transfer 20 percent of their Operating Funds to their Capital Fund, language NAHRO has advocated for strongly over many years.
  • Income Review Safe Harbors – HOTMA would allow PHAs to use other federal data to determine income including TANF, Medicaid, and SNAP.
  • Project-Based Voucher Program – PHAs would be able to calculate project-based vouchers (PBVs) based on authorized units instead of voucher funding. Additionally, those PHAs that have units targeting homeless individuals and families, veterans, elderly households, disabled households, or units in areas where vouchers are difficult to use, would be permitted to project-base up to 30 percent of those targeted units. In other instances, PHA project-based voucher (PBV) assistance may not exceed 25 percent of the units in a project or 25 units, whichever is greater. In areas where vouchers are difficult to use and in census tracts with a poverty rate of equal to or less than 20 percent, PHAs may provide project-based voucher assistance for up to 40 percent of the units in a project. HOTMA allows PBV contracts and extensions of up to 20 years; allows PHAs to permit site-specific waiting lists managed by owners; and clarifies that PHAs may project-base HUD-VASH and Family Unification Project (FUP) vouchers.
  • Extended Family Unification Vouchers – HOTMA would increase the age of eligibility for FUP vouchers from 21 to 24 and make youth who will leave foster care within 90 days and are homeless or at risk of homelessness eligible. S. 3083 contains provisions that would also expand FUP vouchers by allowing eligible youth “who have attained 16 or 17 years” and who have left foster care to remain in the program for up to 36 months.
  • PHAs and LRAs as ESG Subrecipients – HOTMA includes statutory language, supported by NAHRO, that would permit any state or local government receiving Emergency Solutions Grants (ESG) allocations to distribute all or a portion of its grant funds to PHAs and local redevelopment authorities (alongside private nonprofit organizations).
  • Special Assistant for Veterans Affairs and an Annual Supplemental Report – HOTMA would create a new position of Special Assistant for Veterans Affairs that reports directly to the Secretary of HUD and would be responsible for, among other things, ensuring veterans have access to housing programs and homeless assistance, coordinating veteran-related programs at HUD, and serving as a liaison between HUD, the VA, and the USICH, and officials of state, local, regional, and nongovernmental organizations. HOTMA would also require HUD to collaborate on and submit to Congress an annual supplemental report on veteran homelessness.

H.R. 3700 Introduced in Senate – Take Action Now!

~ Georgi Banna

Senate Banking, Housing and Urban Affairs Subcommittee on Housing, Transportation, and Community Development Chairman Tim Scott (R-S.C.), Ranking Member Robert Menendez (D-N.J), Sen. Roy Blunt (R-Mo.), and Sen. Christopher Coons (D-Del.) introduced companion legislation to the Housing Opportunity Through Modernization Act (H.R. 3700) in the Senate today. The Senate bill number is S. 3083.

“NAHRO commends Chairman Tim Scott and Ranking Member Robert Menendez, with Sen. Roy Blunt and Sen. Christopher Coons, on the introduction of the Housing Opportunity Through Modernization Act in the Senate. This common-sense legislation will help public housing authorities across the country do their jobs more efficiently and better serve their residents. NAHRO was honored to have the opportunity to testify at the House Financial Services Committee last fall about this bill and I am thankful to the senators for their commitment to moving it forward,” said John Bohm, Acting NAHRO CEO.

This is a huge victory, but our work is just beginning in the Senate. Send a letter to your senators today urging them to take immediate action on the Senate bill.

For more information, see NAHRO’s coverage of the introduction of H.R. 3700 and the revised version that was approved unanimously by the House in February.

NAHRO Submits Amicus Curiae Brief to the U.S. Supreme Court

~ Georgi Banna

On June 1, 2016, NAHRO partnering with Housing and Development Law Institute (HDLI), Public Housing Authorities Directors Association (PHADA), Council of Large Public Housing Authorities (CLPHA), and Housing Authority Risk Retention Group, Inc. (HARRG) submitted an Amicus Curiae brief in support of the Housing Authority of the City of Los Angeles’s (HACLA) request for their appeal to be heard by the U.S. Supreme Court.

HACLA reduced its Housing Choice Voucher (HCV) Payment Standards and provided a flyer to all voucher holders at the time of the resident’s annual recertification. The flyer stated the effective date and that the new payment standards would not apply until the resident’s “next regular reexamination.” HACLA also held public meetings and sent a “four-week notice” to residents before the payment standard was applied. Two residents filed suit against HACLA claiming HACLA’s failure to provide understandable information about the payment standard change and its one-year application date violated the residents’ constitutional procedural due process rights and various state laws. HACLA prevailed at the trial court level. The residents appealed, and the case was sent back to the trial court. HACLA prevailed again, and the resident appealed again. At this time, the appeal court (U.S. Court of Appeals, Ninth Circuit) ruled in favor of the residents with specific directions for the residents to prevail at the trial court.

Public Housing Agencies (PHAs) around the nation should have certainty about what constitutes notice when changing HCV payment standards, which the current regulation provides. NAHRO will continue to follow the progress of this case (Nozzi v. HACLA) and would like to hear from other PHAs that may be in the same situation.

Click here for NAHRO’s June 15, 2016 Monitor which contains additional analysis on Nozzi v. HACLA (members only).