Special Admin Fees Available for Small Area FMR Implementation

Earlier today, the Housing Voucher Financial Management Division sent a notice via email reiterating that additional administrative fees are available for PHAs that are implementing Small Area Fair Market Rents (FMRs). Eligible activities include but are not limited to the following:

  • Outreach to families and landlords;
  • Development of additional briefing materials;
  • Hiring of additional staff;
  • Staff training;
  • Changing rent reasonableness methodology; and
  • Software modification.

Both PHAs that must mandatorily implement Small Area FMRs and PHAs that choose to voluntarily implement Small Area FMRs are eligible to apply. To apply, PHAs must submit the following:

  1. Letter addressed to Steven Durham, the Director of the Office of Housing Voucher Programs, requesting reimbursement of costs for adoption of Small Area FMRs;
  2. A board resolution confirming the adoption of Small Area FMRs;
  3. Supporting documentation showing expenses incurred or estimated;
  4. Narrative describing how the above expenses tie to Small Area FMR implementation; and
  5. Certification Signature of the Executive Director.

Electronic applications should be submitted no later than 3 pm ET on Friday, Dec. 31, 2018. Applications should be emailed to PIH.Financial.Management.Division@hud.gov. The subject line must include the PHA Code and the text “SAFMR – Special Fee Request.”

The full notice sent in the email can be found here.

[11/13/2018 3:20 pm ET edit – The link above has been revised to reflect that HUD sent another letter correcting a date in the attachment.]

HUD Updates Guidance on EIV System

In late October, HUD published a notice titled “Administrative Guidance for Effective and Mandated Use of the Enterprise Income Verification (EIV) System” (PIH 2018-18). The EIV system is a web-based application that allows PHAs to check employment, wage, unemployment compensation and social security benefit information for Section 8 and Public Housing program participants. The notice updates the previous guidance on EIV by discussing¬† the Income Validation Tool (IVT) Report. The IVT Report replaces the Income Discrepancy Report under the verification reports link. The IVT will be updated monthly. It will provide information on tenant reported income, previous reported income from form HUD-50058, and discrepancies between tenant reported income and information gleaned from HUD data sharing agreements with Health and Human Services and the Social Security Administration.

The notice can be found here.

SAC Conversion Actions to Receive Additional TPV Funding

On October 22, HUD’s Office of Housing Voucher Programs sent a notice to Housing Choice Voucher (HCV) Program Representatives alerting them to a change in how tenant protection vouchers (TPVs) are funded in conversion actions (e.g., demolitions, dispositions, etc.) that are approved by the Special Application Center (SAC). Previously, TPVs would only be funded for occupied units, but with the new notice mailed to program representatives, HUD is announcing that TPVs will be funded for “unoccupied units that were occupied within the previous 24-month period . . . for both Multifamily Housing and Public Housing TPV actions.” This action will apply prospectively (it will not be retroactive) from October 1, 2018.

In other words, for those PHAs who are initiating an action through the Special Application Center, which will remove units from a PHA’s public housing portfolio, HUD will provide voucher funding for both occupied units and unoccupied units (if the unoccupied units were occupied within the previous 24 months of when the application was sent to HUD).

The notice titled “Demolition and/or disposition of public housing property, eligibility for tenant-protection vouchers and associated requirementsPIH 2018-04 (HA) explains the conditions under which PHAs can initiate certain conversion actions and can be found here.

The notice mailed to HCV program representatives detailing the additional TPV funding can be found here.

HUD Now Accepting Applications for MTW Expansion Cohort #1

Late last week, HUD published a notice–titled “Request for Letters of Interest and Applications under the Moving to Work Demonstration Program for Fiscal Year 2019: COHORT #1 – Overall Impact of Moving to Work Flexibility” (PIH-2018-17)–inviting applications for the first cohort of the Moving to Work (MTW) Expansion. The first cohort of the MTW Expansion will include 30 PHAs with 1,000 or fewer aggregate units (including special purpose vouchers).

In addition to laying out the application process for the first cohort of the MTW Expansion plan, the notice also notes the research topic each cohort will examine. The first cohort will examine the overall impact of MTW flexibility, while future cohorts will examine rent reform, work requirements, and landlord incentives. Applying for MTW status with the first cohort is a two-step process including submitting a letter of interest (due January 11, 2019) and submitting a MTW plan and application.

NAHRO will host a MTW application e-briefing for potential first cohort applicants on Wednesday, November 7th from 1:30 to 3 pm ET. Registration for the e-briefing can be found here.

The MTW Operations Notice can be found here.

The first cohort application notice can be found here.

Click below for additional information on the application process.

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NAHRO Submits Comments on AFFH Rule Streamlining

Earlier this week, NAHRO responded to the Department of Housing and Urban Development’s (HUD’s or the Department’s) request for comments on streamlining the Affirmatively Furthering Fair Housing (AFFH) rule by submitting a comment letter. The National Association of Housing and Redevelopment Officials remains committed to following through on the promise of the Fair Housing Act and its duty to affirmatively further fair housing. At the same time, NAHRO believes that to create a workable rule that delivers results while appropriately balancing the goals of the Fair Housing Act with the limited resources found in communities throughout the United States, certain principles should be followed in refining the AFFH rule.

These general principles are as follows:

  • Entities should not be forced to complete analyses on non-housing factors;
  • Entities should not be forced to complete analyses outside their jurisdiction;
  • Additional funding is required to properly conduct fair housing assessments;
  • Housing agencies should be able to complete any required assessments without having to hire a consultant;
  • The Department should accept and approve assessments for entities that have made a good faith effort to comply with the assessment process;
  • The Department should provide clear, regularly updated guidance for completing assessments;
  • The assessments should provide a greater emphasis on place-based solutions; and
  • The Department should closely follow all requirements of the Administrative Procedure Act and any other process requirements required by law.

The comment letter–after providing background on how HUD substantially deviated from modest recommendations of prior technocratic reports by HUD and the Government Accountability Office (GAO) in 2009 and 2010 respectively–responds to specific inquiries requested by HUD. The comment letter also recommends changes to the definition of “Affirmatively Furthering Fair Housing” and “Qualified PHA.”

The full comment letter can be found here.

LocalHousingSolutions.org launched by the Furman Center and Abt Associates

Abt Associates along with the NYU Furman Center, in a press release published earlier today, announced that they would be launching LocalHousingSolutions.org. LocalHousingSolutions.org is a repository-tool of over 80 policies designed to “preserve and strengthen affordability and address a range of other housing objectives.” The tools at the site enable communities to develop strategies that “promote affordability, stability, quality, and choice.”

The launch of the website is only the start of the process of developing policy tools to promote affordability. The website development process is meant to be iterative with stakeholder experiences informing new content, including “case studies that highlight successes and provide insight into lessons learned.” Additionally, there will be additional resources for non-housing, but related policy topics including public health, transportation, and education.

Abt Associates’s press release can be found here.

LocalHousingSolutions.org can be found here.

Vera Expands Opening Doors to Public Housing Initiative

Last week, the Vera Institute of Justice, announced the expansion of its Opening Doors to Public Housing Initiative. The initiative is a “national project that aims to substantially change public housing admissions policies and reduce barriers that prevent people from safely and successfully reentering their communities once released from prison or jail.” Two individual PHAs and two consortia entities were selected after a competitive selection process: Lafayette Housing Authority; Oklahoma City Housing Authority; the Housing Authority of the County of San Diego in collaboration with five other housing authorities; and a consortium of five agencies led by the Delaware State Housing Authority.

These housing authorities will receive up to 12 months of technical assistance to conduct the following activities:

  • “Safely increase access to housing for people with conviction histories or juvenile records to improve reentry outcomes and reduce recidivism rates.
  • Improve the safety of public housing and surrounding communities through the use of reentry housing strategies.
  • Promote collaboration between public housing authorities, law enforcement agencies, and other criminal justice stakeholders to effectively reduce crime and improve reentry outcomes for people leaving prisons and jails.”

Vera’s full press release can be found here.

Vera’s Opening Doors fact sheet can be found here.

 

HUD Increases HCV Administrative Fee Proration to 80%

Yesterday, HUD’s Housing Voucher Financial Management Division sent a letter to PHA Executive Directors and certain Housing Choice Voucher (HCV) Program Representatives announcing that the 2018 administrative fee will increase from 76 percent to 80 percent. The Department notes that the final number may change again based on national leasing behavior and finding additional funding. The additional administrative fee funding will be obligated during September 2018. The Department also notes that for portability, it is recommended that PHAs continue to use the original estimated 76 percent proration from January to July and begin to use the new 80 percent proration in August.

While NAHRO is pleased that HUD has found the funds to increase the administrative fee proration to 80 percent, we will continue to stress to decision-makers in Washington, D.C., the importance of fully funding this account.

The full letter can be found here.

HUD Publishes FY 2019 FMRs

In a notice titled “Fair Market Rents for the Housing Choice Voucher Program, Moderate Rehabilitation Single Room Occupancy, and Other Programs Fiscal Year 2019,” HUD announced the publication of its Fiscal Year (FY) 2019 Fair Market Rents (FMRs). Comments on the FMRs are due by October 1, 2018. The effective date of the FMRs are October 1, 2018.

The methodology used to calculate these FMRs remain the same as it was for the FY 2018 FMRs. The methodology used to calculate these Small Area FMRs remain the same as it was for the FY 2018 Small Area FMRs. The Department is continuing to implement certain changes (which NAHRO commented on) made in calculating FY 2018 Small Area FMRs. Additionally, as mandated by the Small Area FMR rule, HUD is limiting the amount a FMR or Small Area FMR may decrease to no greater than 10 percent.

The notice also discusses the calculation of Renewal Funding Inflation Factors (RFIFs)–the annual inflation factor by which voucher renewal funding is increased. The Department was considering changing how it calculates RFIFs. The Department notes that most comments “directed HUD to continue using FMR surveys in the calculation of RFIFs.” (Read NAHRO’s RFIF comments here.) The Department is still contemplating how best to incorporate research surveys into the calculation of RFIFs.

FY 2019 FMRs can be found here.

FY 2019 Small Area FMRs can be found here.

The notice announcing the publication of the FMRs can be found here.