Notice on HCV Financial Reporting Requirements

In late-Jan., HUD published a notice titled “Financial Reporting Requirements for the Housing Choice Voucher and Mainstream Voucher Program Submitted through the Financial Assessment Subsystem for Public Housing (FASS-PH) and the Voucher Management System (VMS)” (PIH 2021-08). The notice details the requirement for submitting year-end financial information and submitting leasing and cost information through VMS.

There are certain entity-wide reporting requirements for entities with HCV programs and certain other financial reporting requirements. It states that for PHAs with both a public housing program and HCV program, entity-wide information should be submitted through the FASS-PH system. For PHAs that only have HCV programs, the notice provides alternative requirements, depending on whether the PHA with the HCV program is a stand-alone reporting entity; a part of a non-profit agency or non-general-purpose government entity; or part of a larger general-purpose government entity. Certain general-purpose government entities may also be required to procure independent public accountant services for financial and compliance procedures. The Department also requires that the financial data schedule (FDS) be issued as supplementary information to the financial statements.

Housing agencies with HCV programs are required to submit financial statements based on their fiscal year-end date. For those agencies that have a different fiscal year-end dated (based on the larger government entity’s or the larger non-profit’s fiscal year-end date), the notice provides information to align their organization’s fiscal year-end date with HUD’s systems.

The notice provides information on certain other topics. The notice provides information on the financial data schedule due dates depending on the agency’s fiscal year end. The notice also provides information on times when it is appropriate to request a FASS waiver or extension and the process to do so. There is also information on the programs that are required to reported in the financial data schedule (including CARES Act funding). There is also very basic information on the deadlines for VMS data entry. Finally, the notice provides information about non-compliance with HUD requirements and information on the possible administrative fee sanctions.

The full notice can be found here.

HHS Extends CDC Eviction Moratorium to March 31

Earlier today, the Health and Human Services (HHS) Department made available a pre-publication copy of an order extending the Centers for Disease Control and Prevention’s (CDC’s) eviction moratorium. The eviction moratorium has been extended to March 31, 2021. Additionally, the order now also applies to American Samoa–although it had not previously–because COVID-19 cases have now been reported there.

NAHRO members will receive additional information on this order.

A pre-publication copy of the order can be found here.

$20 million NOFA for Competitive FUP Vouchers Published

Yesterday, HUD released a Notice of Funding Availability (NOFA) for $20 million of competitive funding for Family Unification Program (FUP) vouchers. These vouchers are for youth aging out of foster care. The appropriations acts of 2020 and 2021 each contained $10 million in competitive FUP funding for youths aging out of foster care. This notice would distribute the competitive FUP allocations for youth aging out of foster care for both of those years. The Department expects to make approximately 40 awards from the funds. No award will be for less than 3 vouchers, while the maximum award will vary depending on the size of the PHA’s program (25 vouchers for programs with fewer than 500 vouchers; 50 vouchers for programs between and including 500 and 1.999 vouchers; and 75 vouchers for programs with 2,000 or more vouchers). The application deadline is March 22, 2021.

The full NOFA can be found here.

HUD Updates Demolition and Disposition Notice

Earlier today, HUD published PIH 2021-07, titled “Demolition and/or disposition of public housing property, eligibility for tenant-protection vouchers, and associated requirements.” This notice updates PIH 2018-04, which was the prior demolition and disposition notice.

The new notice makes several non-substantive and substantive revisions to the prior notice. Non-substantive revisions include clarifying headings, adding spacing between paragraphs, re-numbering paragraphs, and correcting citations to regulatory provisions, which make for a clearer document. Substantive changes in this notice include the following:

  • HUD’s Special Applications Center (SAC) no longer claims to return a SAC application that is substantially incomplete or deficient, while informing a PHA of its deficiencies (previously, SAC would “return” the application by changing the status of the application to DRAFT in the Inventory Management System/PIH Information Center [IMS/PIC]);
  • The Department clarifies that PHAs must not just make resident consultation accessible, but rather that “PHAs must ensure that communications and materials are accessible to individuals with disabilities and take reasonable steps to provide meaningful access to persons with Limited English Proficiency (LEP)”;
  • Use of proceeds is no longer a material term of the SAC application, so if a PHA’s plan on the use of proceeds changes after HUD approval of an application, a PHA would no longer have to request an amendment to the application;
  • Includes new RAD/Section 18 blends;
    • RAD/Section 18 Construction Blend – the percentage of units eligible for disposition is based on hard construction costs for new construction or rehabilitation of the covered project. Transactions that use the 9 percent Low-Income Housing Tax Credit are not eligible.
      • If hard construction costs equal 90 percent of the Housing Construction Costs (HCC) as published by HUD for a given market area, the PHA may dispose of up to 60 percent of the units of the converting project under Section 18;
        • For high-cost areas (HCC exceeds 120 percent of the national average), a PHA may dispose of up to 80 percent of the units of the converting project under Section 18;
      • If the hard construction costs equal or exceed 60 percent, but are less than 90 percent, of HCC, the a PHA may dispose of up to 40 percent of the units of the converting project under Section 18;
      • If the hard construction costs equal or exceed 30 percent, but are less than 60 percent, of HCC the PHA may dispose of up to 20 percent of the units of the converting project under Section 18;
    • RAD/Section 18 Small PHA Blend – for any PHA with 250 or fewer public housing units under its Annual Contributions Contract (ACC), up to 80 percent of the units in a converting project may be disposed of under Section 18;
  • The Department clarifies that tenant-protection voucher (TPV) requests first go to the field office for a threshold review before being sent to HUD’s Financial Management Division (FMD), while HUD’s Financial Management Center (FMC) notifies PHAs of the final TPV awards.

The full notice can be found here.

Mobility Demonstration Updates

The Department has made several updates to the mobility demonstration website. The mobility demonstration will provide funding to PHAs to research the efficacy and cost of providing mobility-related services to voucher participants.

  • On Jan. 14th, HUD updated their Questions and Answers document.
  • On Jan. 6, HUD held a third webinar on the demonstration. The webinar “provided a deeper dive on the application requirements to help PHAs better understand how to submit a proposal to HUD.” A recording can be found here. Slides from the webinar can be found here.
  • Finally, as mentioned before, HUD has also restricted MTW participation in the mobility demonstration in certain ways.

The Department’s application deadline is Feb. 1, 2021.

Additional information on the mobility demonstration can be found on HUD’s website.

MTW Expansion Applications for Cohorts #3 and #4 Posted

Earlier today, HUD published applications to apply for additional cohorts in the Moving to Work (MTW) Expansion. The Moving to Work program allows PHAs additional regulatory flexibilities to implement innovative strategies to house families. The MTW Expansion incorporates a research component with every new cohort of MTW agencies.

The applications can be found here:

NAHRO members will receive additional information about both applications in the coming days.

Assistant PIH Secretary Resigns from HUD

Assistant Secretary of Public and Indian Housing Hunter Kurtz has resigned from his position, effective at the close of business today.

In an email to housing authority executive directors, Mr. Kurtz wrote: “Being the Assistant Secretary for Public and Indian Housing and working with you over the past 18 months has truly been the greatest honor and privilege of my life. During this time, we have done incredible work, in some of the most challenging times our industry has faced. Most importantly we helped the residents of our programs prepare for and respond to a virus, that disproportionately affected the people we serve.”

NAHRO has had a strong working relationship with Assistant Secretary Kurtz.

“He is a thoughtful leader who cares deeply for HUD programs, our public housing and Indian housing agencies, and the people who they serve,” said NAHRO CEO Adrianne Todman. “We are grateful for his work and wish him the best.”

Mr. Kurtz was confirmed on June 20, 2019. He has spent more than 10 years in federal service. He previously served as the Principal Deputy Assistant Secretary for Public and Indian Housing, and also served in the White House as the Deputy Chief of Staff at the Council of Economic Advisers.

He was also previously the Deputy Director of Detroit’s Department of Housing and Revitalization, where he managed the department’s day-to-day operations, implemented programs that helped homeowners, and oversaw reform of the department’s contract and procurement processes.

HUD Restricts MTW Participation in the Mobility Demonstration

Tomorrow, HUD will publish a notice titled “Section 8 Housing Choice Vouchers: Implementation of the Housing Choice Voucher Mobility Demonstration, Restrictions on Participating in the Mobility Demonstration and the Moving to Work Demonstration Expansion.” To maintain the “Congressionally mandated rigorous evaluation” of the Moving to Work (MTW) Demonstration expansion and the mobility demonstration expansion, HUD is restricting the overlap between MTW agencies and agencies that can participate in the mobility demonstration.

In general, PHAs that participate in MTW Expansion cohorts 2, 3, or 4 may not participate in the mobility demonstration program. Housing agencies that participate in MTW Expansion cohorts 1 or 5 may participate, but will have their MTW flexibilities curtailed.

The restrictions are noted below.

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CARES Act Admin Fee Eligible Uses Revised

On Dec. 10, HUD revised the list of eligible activities for the Coronavirus Aid, Relief, and Economic Security (CARES) Act Administrative Fee Funds for the Housing Choice Voucher (HCV) program. Congress allocated $1.25 billion in administrative fees to HUD to disburse to PHAs. The administrative fees were transferred by HUD to PHAs in two disbursements. The first disbursement occurred in May, while the second occurred in July.

The new coronavirus-related uses of the CARES Act HCV administrative fee are the following:

  • Relocation of PHA staff and participating families to health units or other designated units for vaccination.
  • Hiring of temporary employees to maintain program operations due to coronavirus.
  • Costs related to office improvements, including improved systems for teleworking and/or rental of additional space, to ensure social distancing and other CDC recommended measures.
  • One-time utility deposits to assist families in securing units.

The uses listed above are in addition to regular administrative fee uses and the older coronavirus-related uses HUD had already authorized.

The updated list of eligible uses of CARES Act HCV administrative fees can be found here.