Earlier today, HUD sent a letter to PHA Executive Directors in which HUD states that the Inventory Management System-Public Housing Information Center (IMS/PIC) will not process 50058 submissions from March 13, 2020 to March 23, 2020. During this time, the system will be upgraded to fix a security flaw. Housing agencies are asked to not use the system during this window.
This upgrade is being done to patch a security-related exploit in the system. Current web browsers will soon receive a patch that will make them unable to use the current system because of the exploit. The upgrade will also result in reduced functionality in certain system modules like PIC inventory removal and changes to existing building and unit information. The Department is developing a plan for additional support during this time.
The Department is encouraging PHAs with programs with fiscal years that end December 31 to complete submission of their SEMAP certification prior to the system entering the shutdown (i.e., testing) phase.
The system will resume operation on March 24, 2020. At that time, the Department will publish step by step instructions for PHAs and Field Offices to address potential problems.
As previously mentioned on this blog, the Vera Institute of Justice (Vera) is seeking applications for technical assistance from PHAs that would like to plan and implement reentry programs or change their policies toward people with conviction histories. Applications are due in one week on Friday, February 28, 2020.
The goals of the initiative include the following: increase housing for people with conviction histories while increasing public safety; improve the safety of public housing through the use of reentry strategies; and promote collaboration between PHAs, law enforcement, and other criminal justice stakeholders.
Housing authorities of all sizes (including those with housing choice vouchers) are encouraged to apply. Applicants must submit a letter of intent, an application narrative, and letters of support. Award announcements will be made in April.
Earlier today, HUD announced that it published a Housing Choice Voucher Dashboard. The dashboard provides information about vouchers at both the state and national levels. It includes budget and leasing utilization information, reserve balance information (it highlights PHAs that have high reserves as a percentage of their budget authority and in absolute terms), attrition, per unit cost trends, and leasing potential. There is also utilization data on special purpose vouchers (HUD-VASH, FUP, Mainstream, etc.). The data is mostly taken from the voucher management system.
Earlier this week, HUD was supposed to livestream a Housing Choice Voucher (HCV) Landlord Participation webinar, but was unable to stream it because of technical difficulties. Despite the difficulties, the Department was able to record the webinar and has now made it publicly available. It can be found below.
The notice states that FHA complaints involving requests for reasonable accommodations for assistance animals are on the rise. One of the purposes of this guidance is to help housing providers distinguish between a person with a non-obvious disability who has a legitimate need for an assistance animal and a person without a disability who wants to have a pet (or otherwise circumvent a rule applicable to a pet).
The guidance does several things. First, it provides a framework for identifying service animals. Second, it provides a framework to analyze reasonable accommodation requests under the Fair Housing Act for assistance animals other than service animals (There are two types of assistance animals–“service animals” and “support animals”; the latter are trained or untrained animals that do work, perform tasks, provide assistance, or emotional support for individuals with disabilities that do not fall under the service animals category). Third, the guidance provides criteria for assessing whether to grant a requested accommodation. Fourth, the guidance provides information on which types of animals (i.e., species of animals) are acceptable in which situations. Fifth, the guidance provides additional considerations that must be taken into account.
Additionally, there is a second section of the notice which provides a section on documenting an individual’s need for assistance animals in housing and provides a series of frequently-asked questions and accompanying answers.
The notice lists mainstream voucher policies. It clarifies who the eligible population for these vouchers are (households that include a non-elderly person with disabilities); clarifies that participants do not “age out” of eligibility; highlights that at turnover, all mainstream vouchers must be reissued to the next mainstream-eligible family; reiterates that mainstream vouchers are regular housing choice vouchers (HCVs) with special eligibility criteria; restates that the vouchers are for new admissions of households; and states that a PHA may only have one waiting list for all tenant-based assistance.
Additionally, the Department discusses admissions preferences. First, preferences apply to all vouchers, not only Mainstream vouchers. If a PHA claimed a preference in its notice of funding availability (NOFA) application, then the PHA must adopt a preference for at least one of the targeted groups in the NOFA. Additionally, PHAs may limit the number of applicants who qualify for the preference. The PHA also has the option to open the PHA waiting list for a limited preference. Finally, the PHA must update preference policies and procedures on how preferences will be applied.
The notice also discusses waiting list updates, portability, funding, tracking and monitoring these vouchers, and partnerships and supportive services. Questions about the program can be directed to MainstreamVouchers@hud.gov.
Qualities of the HCV program that attract landlords:
Helping people who need housing;
Receiving a stable, reliable source of income from HUD;
Required by law in some jurisdictions to accept vouchers; and
Existence of damage mitigation programs which help landlords repair tenant-caused damages;
Qualities of the HCV program that drive off landlords:
No single point of contact for landlords and other communication deficiencies;
Delays in the inspection process;
Lack of consistency between inspections;
Not being informed of changed appointment times by inspectors;
Too few inspectors;
Not being informed of cancelled appointments in a timely manner;
Lacking a mechanism of collecting on tenant-caused damages;
Lacking a way to remove damage-causing tenants;
Requirements to repair a unit;
Unknown tenant-caused damages cause units to fail inspections;
Application and Move-in;
approved rent amounts;
length of time for application approval; and
Voucher and Approved Rent amount;
Lack of clarity about required amenities and conditions of units;
Fair Market Rents (FMRs) not keeping pace with the local market;
Lack of being able to submit paperwork electronically;
Lack of staff that could approve cases during holidays and vacation times;
Confusion over widely varying rent amounts in areas that use Small Area FMRs;
Annoyance at the different paperwork and rules for each PHA, in areas where there are multiple PHAs with overlapping jurisdictions;
Cumbersome process to access damage mitigation funds in those areas which use them; and
The requirement to treat voucher holders differently by requiring a one-year lease initially, when the norm in the market is month-to-month leases.
While the causes of landlord dissatisfaction are multi-faceted and may vary by jurisdiction, NAHRO believes that fully funding the administrative fee account will help PHAs address many of these issues.
The above is a brief outline of the report and excludes details for added brevity. The full summary can be found here.
Earlier this week, HUD published a new proposed fair housing rule titled “Fair Housing Act Design and Construction Requirements; Adoption of Additional Safe Harbors.” The Fair Housing Act provides that unlawful discrimination against persons with disabilities includes the failure to properly design and construct certain multifamily dwellings. This proposed rule would amend HUD’s regulations to incorporate the 2009 edition of International Code Council (ICC) Accessible and Usable Building and Facilities (ICC A117.1-2009) as satisfying the design and construction requirements of the Fair Housing Act. The proposed rule would also designate the 2009, 2012, 2015, and 2018 editions of the International Building Code (IBC) as safe harbors under the Fair Housing Act.
Comments on this proposed rule are due on March 16, 2020.
The Vera Institute of Justice (Vera) is offering a webinar that promises to inform potential applicants about the goals of the Opening Doors to Public Housing Initiative. The Opening Doors to Public Housing Initiative seeks to provide technical assistance to PHAs that wish to plan and implement reentry programs or change their admissions policies for people with conviction histories. Additionally, the webinar will provide an overview of the application requirements, allow time for questions from interested applicants, and present applicants from past Opening Doors sites who will share their experiences implementing reentry programs and changing their housing policies.
Housing authorities and their justice system partners are strongly encouraged to participate in the webinar, though it is open to all.
Opening Doors to Public Housing (Friday, January 17, 2020 at 1 pm ET)
Presenters include the following:
Andre Bethea, Policy Advisor, Corrections, Bureau of Justice Assistance, Office of Justice Programs, U.S. Department of Justice;
Laura Gregory, Resident Services Manager, Oklahoma City Housing Authority; and
Julio Sanchez, Senior Probation & Parole Officer, Delaware Correctional Reentry Commission (DCRC) In-reach Coordinator, Georgetown Probation & Parole.