Author: Jenny Hsu

Interactive Tool Shows the Challenges in Affordable Housing Development

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The Urban Institute and National Housing Conference have published an interactive and educative tool, “The Cost of Affordable Housing: Does It Pencil Out,” that demonstrates the huge gap between what it costs to build and maintain affordable housing and the affordable rent that low-income families can pay, making it difficult to finance affordable housing without additional subsidy. Aimed at policymakers and those new to the affordable housing world, users can play with the tool by changing specific variables on development costs and see how a development’s funding gap can be closed. The tool spotlights the importance of federal programs that support affordable housing, such as the Low-Income Housing Tax Credit (LIHTC) – which is the largest source of capital supporting the affordable housing inventory in the United States.

The formidable gap in financing affordable housing development is why it is important for the public to call on Congress to pass Sen. Maria Cantwell’s (D-Wash.) and Sen. Orrin Hatch’s (R-Utah) Affordable Housing Improvement Act of 2016. This legislation would expand the overall LIHTC allocation authority by 50 percent and make permanent the 4 percent Housing Credit rate. For more information on this legislation, visit NAHRO’s Community Development Resource Center (log-in required) to access a one-pager on the bills.

HUD Publishes Integrity Bulletins for CPD Formula Grantees

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The HUD Offices of the Inspector General (OIG) and Community Planning and Development (CPD) have developed Integrity Bulletins that cover topics representing issues that CPD formula grantees often struggle with: procurement and contracting; sub-recipient oversight; conflicts of interest; internal controls; documentation and reporting; and financial management.

The four Integrity Bulletins available include:

HUD Publishes Housing Trust Fund Income Limits and Guidance on Environmental Provisions

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In May 2016, HUD announced the first-ever National Housing Trust Fund (HTF) allocations to states, amounting to nearly $174 million in available funds for FY 2016. HUD recently published the HTF Income Limits for FY 2016, which are calculated using the following methodologies:

  • The formula that HUD uses for calculating the income limits for the Section 8 program, in accordance with Section 3(b)(2) of the U.S. Housing Act of 1937, as amended. These limits are based on HUD estimates of median family income, with adjustments based on family size.
  • The Federal Poverty Line as determined by the U.S. Department of Health and Human services, published annually in the Federal Register.

In years in which the total amount available for allocations is below $1 billion (as is the case for FY 2016), the income limit reports will only display the limit for extremely low income families or families with incomes at or below the poverty line (whichever is greater) and will not include the very low income limit. The HTF FY 2016  Rent Limits are also available online, both limits became effective on July 1, 2016.

Additionally, HUD has made available new guidance entitled, “Requirements for Housing Trust Fund Environmental Provisions.” This notice describes the Environmental Provisions for new construction and rehabilitation that are required for HTF projects under the Property Standards at 24 CFR § 93.301(f)(1) and (2).

Moving On from Supportive Housing Toolkit

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Corporation for Supportive Housing (CSH) has developed a new Moving On Toolkit for supportive housing providers, Continuums of Care, PHAs, state and local government agencies and other organizations that would like to plan, develop, sustain and evaluate Moving On initiatives within their communities. Moving On initiatives provide rental subsidy and transition assistance to tenants who are able and want to move out of supportive housing and into a new apartment. The toolkit outlines the various phases and steps in the Moving On process and offers numerous links and helpful resources, including descriptions of previous or existing Moving On projects and practical tools or templates developed by implementing organizations. According to CSH, the fundamental goal of Moving On is to promote the highest levels of independence and choice for tenants. HUD has previously provided public support for Moving On but current initiatives only exist on a small scale through scattered pilots.

HUD Updates Notice on Prioritizing the Chronically Homeless in Permanent Supportive Housing

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On July 25, 2016, HUD published Notice CPD-16-11 entitled, “Notice Prioritizing Persons Experiencing Chronic Homelessness and Other Vulnerable Homeless Persons in Permanent Supportive Housing.” This notice supersedes the previous Notice CPD-14-012, and provides guidance to Continuums of Care (CoC) and recipients of CoC Program funding for permanent supportive housing (PSH) regarding the order in which eligible households should be served in all CoC Program-funded PSH. This Notice reflects the new definition of chronically homeless as amended by the HUD Final Rule on Defining “Chronically Homeless” and updates the orders of priority that were established under the prior Notice.

CoCs that previously adopted the orders of priority established in Notice CPD-14-012 and who received points for having done so in the FY 2015 CoC Program Competition are encouraged to update their written standards to reflect the updates to the orders of priority as established in this updated Notice. CoCs that have not previously adopted the orders of priority established in Notice CPD- 14-012 are also encouraged to incorporate the orders of priority included in this Notice into their written standards.

Access Notice CPD-16-11 here.

Learn more about HUD’s Final Rule on Defining “Chronically Homeless” here (NAHRO login required).

NAHRO Publishes New RAD Toolkit

~ Jenny Hsu

Last week, NAHRO published the “RAD Toolkit,” a new online resource that serves as a primer for PHAs interested in HUD’s Rental Assistance Demonstration (RAD) program. This educative tool will provide PHAs with a background on RAD, a step-by-step outline of the conversion process and compliance, as well as links to additional resources important to understanding how to close a RAD transaction.

The RAD Toolkit was developed by the NAHRO Community Revitalization and Development (CR&D) Committee Redevelopment Task Force.

NAHRO members can access the toolkit here: www.nahro.org/RAD.

RADTOOLKIT2

New HUD Guidance on the Review Process for Assessments of Fair Housing

~ Jenny Hsu

Last week, HUD published a new document that will assist program participants in understanding how the Department will conduct its review of an Assessment of Fair Housing (AFH) and apply the two standards established in Section 5.162 of the Affirmatively Furthering Fair Housing (AFFH) Final Rule. HUD will not accept an AFH if:

  1. The AFH is inconsistent with fair housing or civil rights requirements; or
  2. The AFH is substantially incomplete.

The document also describes the general principles that will guide HUD reviewers as they apply the two standards and additional information related to HUD’s review. Also included are examples of reasons that HUD will not accept an AFH, an explanation of why the AFH would be substantially incomplete or inconsistent with fair housing or civil rights requirements, and the corrective actions HUD will seek.

Visit the NAHRO Resource Center for more information on the AFFH rule and requirements.

HUD Awards 10 Choice Neighborhoods Planning Grants

~ Jenny Hsu

On June 28, HUD awarded $8 million in Choice Neighborhoods Planning grants to 10 communities across the nation. The Choice Neighborhoods Initiative (CNI) helps struggling neighborhoods with severely distressed public housing or HUD-assisted housing by comprehensively investing in the community’s housing, residents and neighbors. Planning Grants, which assist communities in developing their comprehensive neighborhood revitalization plan or “Transformation Plan,” is one of two types of grants offered through the Initiative. Implementation Grants, which support communities that are ready to implement their Transformation Plan, are also funded through this program.

HUD is awarding Choice Neighborhood Planning funds to the following grantees:

  • Asbury Park Housing Authority, New Jersey
  • Housing Authority of the City of Brownsville, Texas
  • Greater Dayton Premier Management, Ohio
  • Louisville Metro Housing Authority, Kentucky
  • Metropolitan Development and Housing Authority (Nashville, Tennessee)
  • City of Newport News, Virginia
  • City of Phoenix, Arizona
  • Housing Authority of the City of Pittsburgh, Pennsylvania
  • Sanford Housing Authority, Florida
  • City of Shreveport, Louisiana

Prior to the funding announcement for the FY 2015/FY 2016 Choice Neighborhoods Planning Grant last November, Planning Grant funds could only be used for the creation of a Transformation Plan. HUD has now introduced a new component called Planning and Action Grants that will allow communities to use grants of up to $2 million over three years to demonstrate a commitment to “doing while planning.”

During the planning process, communities will identify Action Activities to be carried out during the latter portion of the grant period that must build upon the planning for the target housing and neighborhood. Eligible Action Activities may include reclaiming and recycling vacant property into community gardens, pocket parks, farmers’ markets, or land banking; beautification, placemaking, and community arts projects; homeowner and business façade improvement programs; neighborhood broadband/Wi-Fi; fresh food initiatives; and gap financing for economic development projects. The inspiration for this new component comes from the 63 previously awarded Planning Grantees that showed “tangible, early actions help sustain community energy, attract new resources, and build momentum to turn that plan into reality.”

Read comprehensive summaries of the 10 Choice Neighborhoods Planning grants here.

HUD Opens FY 2016 Continuum of Care Competition

~ Jenny Hsu

Yesterday, HUD published the FY 2016 Continuum of Care (CoC) Program Competition Notice of Funding Availability (NOFA), making $1.9 billion available in funds available for continuums across the nation. For this competition, the total amount of funding available may not cover all anticipated eligible renewal projects and HUD continues to require CoCs to rank their projects into two tiers (Tier 1 and Tier 2). The submission deadline for this competition is Wednesday, September 14, 2016.

A few notable changes to this year’s NOFA include:

  • Changes to Tiers: Funding for Tier 1 this year is equal to 93 percent of the CoC’s Annual Renewal Demand (ARD). This is an increase from 85 percent last year, which means CoCs will have a the better opportunity to protect those higher priority projects and fewer projects will be in jeopardy of cut funds.
  • New Policy Priority: Creating a systematic response to homelessness is a new policy priority this year. According to a recent CoC Competition Focus message from HUD, having a systemic response to homelessness requires establishing a coordinated entry system, cohesive planning by the entire community, making assistance appealing and accessible, and using system performance measures.
  • Additional Points: System performance and reallocation will be worth more points in this NOFA. Beginning this year, CoCs are now required to report their system performance measures into HUD’s Homeless Data Exchange (HDX) by August 1, 2016. For this competition, a CoC could receive up to 10 points for attaching their system performance measures report to it’s application.

HUD’s announcement for the competition also included a message encouraging CoCs to reallocate funds from lower performing transitional housing projects serving households fleeing domestic violence to other types of projects serving people fleeing domestic violence. This would “ensure that CoC-funded projects serving people fleeing domestic violence are as effective as possible.” HUD will soon release further guidance on this issue.

New CoC Interim Rule Will Increase Mobility for Homeless Individuals and Families

~ Jenny Hsu

On June 14, 2016, HUD published the interim rule “Continuum of Care Program-Increasing Mobility Options for Homeless Individuals and Families with Tenant-Based Rental Assistance,” which will apply two amendments to the Continuum of Care (CoC) program regulations. The first amendment will permit program participants to retain their tenant-based rental assistance (TBRA) if the individual or family moves outside of their CoC’s geographical area. The second amendment will exempt CoC recipients and subrecipients from complying with all non-statutory program regulations when a program participant moves in order to flee domestic violence, dating violence, sexual assault, or stalking. HUD has elected to forego an advance notice for public comment because “a delay would be contrary to the public interest.” The interim rule becomes effective on July 15, 2016, but public comment will be accepted until August 15, 2016.

HUD is seeking comments from providers on the impact of exempting CoC recipients and subrecipients from non-statutory requirements when a program participant moves outside the CoC area to flee an imminent threat/violence and when participants request to move outside the area in order to access better opportunities and resources, and to support mobility. Comments are accepted online at: https://federalregister.gov/a/2016-13684.