HUD REAC OED Publishes First Newsletter – Gives UPCS-V Update

HUD REAC’s Oversight and Evaluation Division (OED) published its first newsletter earlier today. The newsletter, which is distributed by email, offers program updates and statistics on the UPCS-V Demonstration.

Here are a few points stressed in the newsletter:

  • HUD anticipates UPCS-V version 3 to be published by the end of Summer 2017.
  • HUD is interested in learning about landlord events from PHAs. OED staff will do their best to attend these events (in-person or via a conference call) to learn more about landlord concerns.
  • HUD has reformatted decision trees and is making several updates to the inspection software, which it is currently being tested in HUD’s control environment. HUD anticipates a release of the update during the first part of May.
  • OED staff has trained housing authority staff through in-person and virtual trainings.
  • The Powerpoint and a recording of the third conference call can be found on the OED website. [At the time of this posting, NAHRO staff were unable to locate the link to the 2/28/17 conference call PowerPoint.]
  • Current UPCS-V statistics:
    • 237 Demonstration volunteers (13 spots open);
    • 24 PHAs trained; and
    • 683 UPCS-V inspections completed by PHAs.

Certain HOTMA Voucher Provisions Become Effective Today

Today, April 18, 2017, some of The Housing Opportunity Through Modernization Act of 2016‘s (HOTMA’s) voucher provisions take effect.[1] Here is a list of the HOTMA provisions–and a very brief summary of each provision–that you can use, as of today.[2] [3] Implementing some of these provisions may require changes to your administrative plan or HUD notification.

  • HOTMA: Implementation of Various Section 8 Provisions (Effective Date: April 18, 2017);
    • Inspections of Dwelling Units;
      • Occupancy Prior to Meeting HQS – PHAs may approve a unit and commence HAP, even if the unit fails a HQS inspection (with only non-life-threatening HQS deficiencies);
      • Alternative Initial Inspections – PHAs may authorize occupancy of a unit before a PHA’s HQS inspection, if in the previous 2 years, the unit passed a LIHTC, HOME, or other qualified alternative inspection;
    • Units Owned by a PHA;
      • Units Owned by a PHA – a unit is owned by a PHA if it is (1) owned by a PHA; (2) owned by an entity wholly controlled by the PHA; or (3) owned by a LLC or limited partnership in which the PHA holds a controlling interest in the managing member or general partner; and the PHA has a ownership interest in the building itself;
    • Project-based Vouchers (PBVs);
      • PBV General Cap;
        • The PBV general cap of 20 percent may be calculated by unit allocation or funding allocation;
        • The PBV general cap limit is increased by an additional 10 percent for units serving homeless families; families with veterans; supportive housing for the elderly or people with disabilities; or in areas where vouchers are hard to use;
        • Certain other projects are excluded from this cap;
      • PBV Income-Mixing Cap;
        • The income-mixing cap is now the greater of 25 units in a project or 25 percent of the units in a project;
        • Certain other projects are exempted from this cap;
      • Contract Terms – PBV contracts may now extend to 20 years and be extended for an additional 20 years;
      • Selection Preferences – PHAs may establish a selection preference for families who qualify for voluntary services offered in conjunction with assisted units, provided that the preference is consistent with the PHA plan;
      • Attaching Assistance – PHAs may attach assistance to structures in which the PHA has an ownership interest without following a competitive process; Ownership interest is more loosely defined than “units owned by a PHA” for the purposes of this provision;
      • HUD-VASH and FUP Vouchers – PHAs may project-base HUD-VASH and FUP vouchers;
    • Vouchers in Manufactured Housing;
      • Manufactured Home Owner Rent Definition Expanded – the definition of rent for PHAs making voucher assistance available to manufactured home owners has been expanded; The definition of rent now includes, among other things, monthly payments made by a household to amortize the cost of purchasing the manufactured home.

Additionally, you may want to read our previous post on HOTMA’s self-implementing provisions.

[1] – There was speculation that the effective date would be delayed by HUD, but HUD has not published any notices in the Federal Register indicating a delayed effective date, therefore NAHRO believes that the initial April 18, 2017 effective date remains in place.
[2] – Please keep in mind that these are short summaries of the HOTMA voucher provisions. Provisions may have additional requirements as a precondition for their use.
[3] – Although these provisions are effective today, they are still subject to change by HUD.
[4/25/17 edit – removed the word “Standards” after HQS in the “Inspections of Dwelling Units” section.]

HUD REAC Posts Industry Day Materials

As mentioned in an earlier post, HUD held two IT vendor days in Phoenix, AZ and Jacksonville, FL on April 5th and April 7th respectively. HUD has posted the PowerPoints from those two days. They are listed below:

  • PIC-NG Overview – provides a broad overview of PIC – Next Generation, including the rationale for overhauling PIC.
  • PIC-NG Details – provides more detailed information on the functioning of the new system. More technical in nature than the PowerPoint above.
  • Federal Lifeline Program Overview – provides an overview of the Federal lifeline program, which gives a monthly discount of $9.25 to eligible low-income users (or more for Tribal or Native residents) on phone and broadband service.
  • PIC-NG VMS – provides a rationale for changing the Voucher Management System.
  • IT Vendor Deck – provides a discussion on the status of UPCS-V for IT Vendors.
  • Exam Data Exchange – provides a discussion of tailoring software to work with HUD’s ExAM and Salesforce created programs.

NAHRO is currently examining the materials.

The website listing all the REAC Industry Day Materials can be found here.

Vera Institute of Justice Offering Technical Assistance for PHAs Implementing Reentry Programs

The Vera Institute of Justice is soliciting applications for technical assistance from PHAs, including those PHAs running Housing Choice Voucher Programs, who seek to implement reentry programs or to change their policies for the purpose of increasing access to housing for people with conviction histories.

PHAs of all sizes and in all geographies are invited to apply. Additionally, PHAs that are in the same geographic area may apply together in a single application, if they have common goals and coordination would facilitate achieving those goals.

The program is offering nine months of technical assistance. Technical assistance includes meeting with PHA staff; meeting with local stakeholders; data analysis identifying the number of potentially barred individuals; policy assistance changing or drafting a PHA’s policy towards individuals with records; access to local consultants; assistance implementing policy change; data analysis after implementation of policy changes; and potential opportunities to foster cross-site learning. PHAs are expected to identify a primary liaison and assist with developing a group of interested community stakeholders. There are no financial commitments for PHAs.

To apply, interested PHAs should send (as a PDF) the following: (1) a letter of intent or commitment; (2) an application narrative; and (3) optional, but recommended, letters of support. All documentation should be sent to kfinley@vera.org.

Applications will be accepted until May 12, 2017. Vera staff will conduct interviews with some applicants and selected sites will be announced in June.

The entire “Request for Proposals for Technical Assistance” can be found here.

Learn more about the Vera Institute of Justice here.

 

TPV Funding for FY 2016 Announced

Today, HUD published a list of funding awards for Tenant Protection Vouchers (TPVs) for FY 2016. These vouchers are funded non-competitively on an as-needed basis. They are funded on a first-come, first-serve basis for households that are displaced due to HUD program actions.

TPVS were awarded for the following actions:

  1. to assist families living in HUD-owned properties that are being sold;
  2. to assist families affected by the expiration or termination of their Project-based Section 8 and Moderate Rehabilitation contracts;
  3. to assist families in properties where the owner has prepaid the HUD mortgage;
  4. to assist families in projects where the Rental Supplement and Rental Assistance Payments contracts are expiring (RAD—Second Component);
  5. to provide relocation housing assistance in connection with the demolition of public housing;
  6. to provide replacement housing assistance for single room occupancy (SRO) units that fail housing quality standards (HQS);
  7. to assist families in public housing developments that are scheduled for demolition in connection with a HUD-approved HOPE VI revitalization or demolition grant; and (8) to assist families consistent with PIH Notice 2016-12, “Funding Availability for Tenant-Protection Vouchers for Certain At-Risk Households in Low-Vacancy Areas—Fiscal Year 2016” and PIH Notice 2015-07, “Funding Availability for Tenant-Protection Vouchers for Certain At-Risk Households in Low-Vacancy Areas—Fiscal Year 2015.”

In total, HUD awarded $86,970,667 for 9,606 housing choice vouchers. The notice lists the awardees alphabetically by state.

The full notice can be read here.

HUD to Host MTW Listening Sessions

Earlier today, a NAHRO member forwarded an email sent by General Deputy Assistant Secretary Bryon of HUD’s Office of Public and Indian Housing announcing four listening sessions “for PHAs that are interested in applying to MTW and other industry partners.” Through the listening sessions, HUD hopes to hear feedback on its MTW Operations Notice. The MTW Operations Notice will govern the operation of PHAs that are selected to participate in the 100 PHA Expansion of the MTW Demonstration Program.

HUD is particularly interested in feedback on the following topics:

  • Evaluation and performance assessment;
  • Calculation of funding;
  • Statutory and regulatory waivers; and
  • Regionalization.

The listening sessions will be held in the following cities on the dates listed next to location (click on the location to register):

NAHRO’s comments on the MTW Operations Notice can be found here.

NAHRO Releases Preliminary Joint FY 2018 Budget Recommendations with PHADA and CLPHA

Yesterday, April 6, NAHRO released joint budget recommendations with industry groups CLPHA and PHADA. The document containing the recommendations states that the recommendations “are based on the best information available at this time. [The three groups] will submit revised funding recommendations to Congress when more detailed and timely information, such as the President’s FY 2018 budget request and Congressional Justifications, becomes available in May.”

These recommendations would fully fund the Operating Fund and provide enough funding for the Capital Fund for PHAs to begin addressing their capital needs backlog. Additionally, these recommendations would fully fund voucher renewals, fully fund the administrative fee formula, and fully fund project-based rental assistance contracts. The recommendations also provide sustainable funding for other important programs.

NAHRO / PHADA / CLPHA FY 2018 Funding Recommendations (in millions)
Public Housing Operating Fund $5,349
Public Housing Capital Fund $5,000
Emergency Capital Needs $21.5
Resident Opportunities and Supportive Services (ROSS) $35
Jobs Plus $15
Public Housing Financial and Physical Assessment Activities $10
Section 8 Tenant-Based Housing Choice Voucher HAP Renewal $19,390
Section 8 Ongoing Administrative Fees $2,284
Section 8 Project-Based Rental Assistance $11,400
Consolidated Family Self-Sufficiency (FSS) Program $95
Choice Neighborhoods Initiative $200

The “Emergency Capital Needs,” “Resident Opportunities and Supportive Services (ROSS),” “Jobs Plus,” and “Public Housing Financial and Physical Assessment Activities” accounts are in addition to the amount requested for the Capital Fund and are not sub-accounts.

The entire document with the FY 2018 budget recommendations–which contains additional information about each of the accounts–can be found here.

Information for Volunteering PHA Properties for UPCS Inspector Field Training

During one of the panels at NAHRO’s 2017 Washington Conference, a panelist mentioned a program where PHAs could volunteer their properties to participate in a program to train UPCS Phase II inspector candidates. In return for volunteering properties, the PHA would receive a free “Pre-REAC” non-scored inspection.

NAHRO staff agreed to post information on how PHAs could volunteer for the program. To volunteer, PHAs are required to complete a spreadsheet and submit it to reac_quality_assurance@hud.gov. After gathering information on each property from owners, REAC will create a database of all properties to be used for the inspector candidate training process.

Finally, additional questions to REAC on any of the initiatives they are working on (e.g., UPCS-V, PIC-NG, PHAS, or SEMAP) can be emailed to PHAInfoSessions@hud.gov.

A more detailed description of the program can be found here.

The spreadsheet to be filled out with information on particular properties can be found here.

Revised FY 2017 FMRs Posted

On March 30, HUD published a notice titled “Fair Market Rents for the Housing Choice Voucher Program and Moderate Rehabilitation Single Room Occupancy Program Fiscal Year 2017; Revised.” The notice revises the Fair Market Rents (FMRs) for Portland, ME and Vallejo-Fairfield, CA. Additionally, the notice also responds to comments that were submitted by NAHRO and other interested stakeholders on how FMRs are calculated and what constitutes a “material change” in FMR estimation. While summarizing all the stakeholder comments and HUD’s responses is outside the scope of this blog post, listed below is one comment NAHRO articulated in its comment letter and HUD’s response.

The original notice publishing FY 2017 FMRs noted that The Housing Opportunity Through Modernization Act of 2016 (HOTMA) required that HUD seek comment on “any proposed ‘material changes’ in methodology.” HUD sought comment on what should be considered “material changes.”

In its comment letter, NAHRO wrote the following:

HUD should take an expansive view of what constitutes a “material change” in FMR estimation methods . . . NAHRO’s rationale behind this recommendation stems from NAHRO’s belief in open, transparent government that clearly explains its reasoning behind changes and allows feedback, which NAHRO believes is in the best interest of program participants and all other interested stakeholders. (Page 3 and 4.)

HUD responded by writing:

HUD appreciates this comment and HUD is taking an expansive view on what constitutes a “material change” and intends to provide an opportunity for public comment on all FMR methodological changes in forthcoming proposed notices of material changes in FMR calculations.

This is welcome news because it ensures that HUD will not change the methodology for calculating FMRs without allowing NAHRO and other interested stakeholders to offer input.

The rest of HUD’s responses to NAHRO’s comments and the comments of other stakeholder can be found in the notice (along with the revised FMRs) here.

HUD Publishes Cash Management Notice for HCV Program

Yesterday, March 23, HUD published PIH-2017-06, a notice titled “Cash Management Requirements for the Housing Choice Voucher Program.” This notice replaces the previous cash management notice (PIH 2011-67) and “revises the cash reconciliation timeframes and provides additional guidance to MTW PHAs.”

While NAHRO will provide additional coverage of the notice in its the next issue of its newsletter, the Monitor, here are few points from the notice.

  • Monthly disbursements are based on the most recent validated Voucher Management System (VMS) Housing Assistance Payment (HAP) costs. Disbursements may be scheduled for one or multiple months at a time. Disbursements will be made on the first business day of the month. The notice provides an example document showing how PHAs will be notified of disbursements.
  • HUD assesses national program cost trends and may include small increases or decreases to disbursement amounts to account for increases or decreases in national leasing or other costs.
  • PHAs whose monthly costs exceed the scheduled disbursements may submit a request for additional advance to their Financial Analyst at the Financial Management Center (FMC).
  • Disbursements will be scheduled for deposit in a PHA’s bank on the first business day of the month.
  • At least twice a year HUD will compare a PHA’s actual costs to funds disbursed plus other program revenues (e.g., fraud recoveries). Future disbursements will be adjusted accordingly. HUD will address disbursement shortfalls at a reconciliation at the end of the calendar year. In the end-of-the-year reconciliation, if HAP expenses were less than total HAP disbursement combined with other program revenue and Restricted Net Position (RNP), there will be an offset.
  • HUD will process prior period adjustments once in the next year.
  • The notice provides a sample document HUD will use following each interim and year-end cash reconciliation.
  • Incremental vouchers (i.e., first time vouchers) such as HUD-VASH or tenant protection vouchers will have their funding disbursed in equal monthly amounts according to the effective date and expiration dates of their contracts.
  • Excess HAP and RNP are to be deposited in an interest-bearing account and at least once a year, PHAs are required to remit that interest to the Treasury.
  • PHAs are still able to access their program reserves for eligible HAP needs whenever necessary by contacting their Financial Analyst at FMC.

MTW Agencies

MTW agencies are subject to cash management requirements. Non-HAP expenses funded from HAP are not considered for the monthly HAP disbursement calculations. Any MTW PHA that needs more than the calculated amount should contact their Financial Analyst at the FMC for additional disbursement, which may include eligible MTW non-HAP expenses.

Additional coverage on the notice will be forthcoming for members. The notice can be read here.