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 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.
Earlier this morning, HUD sent an email to Executive Directors with hyperlinks to items mentioned in their 2017 HCV Program Renewal Funding Letter. Due to the brevity of the message, I’ve reproduced it completely below.
Dear Executive Director,
The purpose of this communication is to follow-up on the March 15, 2017 letter regarding the regarding the status of calendar year 2017 Housing Choice Voucher Program’s renewal funding. The letter referenced links to the House and Senate 2017 Bills as well as the Field Offices’ Two-year Forecasting Tool, and it has come to HUD’s attention that the links were not active. Below you will find the links to the House and Senate Bills and to the Two-year forecasting tool.
TBRA Senate Report
TBRA House Report
Forecasting tool link
Thank you for your participation in the HCV program.
The original letter can be found here.
Today, March 15, HUD sent a letter to Executive Directors about 2017 Housing Choice Voucher (HCV) renewal funding. The letter purports to provide guidance in HCV Program planning.
The letter notes that the Department would normally have 60 days to calculate a PHA’s funding level after a full-year budget or a full-year Continuing Resolution (CR), but currently the Department has neither a full-year budget nor a full-year CR and is operating under a CR that is a few months long. It is operating under a CR that lasts until April 28, 2017. This partial-year CR makes planning difficult. HUD believes that they will only have definitive budgetary information for FY 2017 in June 2017.
Despite this, HUD has evaluated several situations to provide PHAs with potential guidance in HCV Program planning. The letter notes that in calculating national voucher costs a significant inflation factor was applied. There was at least a 2.58% inflation factor applied to all PHAs. Forty percent of PHAs received a higher inflation factor.
- Scenario 1 – Full Year CR (FY 2016 Appropriation Levels):
- HAP proration – 94% and
- Administrative Fee proration – 77%.
- Scenario 2- Full Year budget passed:
- Using Senate Appropriations bill numbers:
- HAP proration – 97.5% and
- Administrative Fee proration – 80%.
- Using House Appropriations bill numbers:
- HAP proration – 97.5% and
- Administrative Fee proration – 75%. [4:03 pm edit – number corrected.]
The letter states that “a full year CR seems to be the responsible starting point for program operations . . . [and] PHAs should assess their projected leasing and spending starting with the 94% proration . . . [and] model alternative scenarios.” HUD also recommends using the HCV Forecasting Tool and modeling different proration scenarios (the forecast tool defaults to 94% currently).
NAHRO agrees that it is safe assumption to assume a full year CR for FY 2017 in program planning.
The full letter can be read here.
HUD Oversight and Evaluation Division has posted the latest (2/28/17) UPCS-V conference call for this quarter. The call provided updates about how the UPCS-V Demonstration was proceeding and HUD’s planned next steps.
The conference call can be downloaded here.
For a quick overview of some key points in the conference call, our prior post on it can be found here.
On March 3, HUD published PIH-2017-04 (HA) titled “Limitations on Payments to Influence Federal Transactions for PIH Programs and PHA Anti-Lobbying Certification and Disclosure Requirements.” According to this notice, PHAs are required to submit the following, if they have received over $100,000 in federally appropriated funds:
- Certification of Payments to Influence Federal Transactions (Form HUD-50071) – for PHAs to certify that they have not and will not make prohibited payments from federally appropriated funds; and
- Disclosure of Lobbying Activities (SF-LLL) – for PHAs that have used non-federally appropriated funds for influencing or attempting to influence executive or legislative branch personnel in connection with new funding, renewal funding, changing policy, or changing legislation.
PHAs are prohibited from using federally appropriated funds for lobbying activities. PHAs’ contributions to trade associations are not lobbying activities under this notice, nor do the certification and disclosure requirements in this notice apply to PHA contributions to trade associations. The requirements of this notice apply to all PHAs, including MTW agencies.
The notice also outlines record retention and other responsibilities of both PHAs and HUD Field Offices.
Additional information on the notice will be provided to NAHRO members in upcoming coverage.
The full notice can be found here.
Earlier today, the United States Senate confirmed Dr. Ben Carson as the 17th Secretary of the United States Department of Housing and Urban Development. He was confirmed on a vote of 58 to 41. NAHRO has invited Secretary Carson to speak at the 2017 NAHRO Washington Conference. NAHRO has also invited the Secretary to listen to the concerns of PHAs and RDAs as part of the countrywide listening tour he mentioned during his confirmation hearing. We look forward to working with him.
[3/3/17 Edit – HUD’s press release can be found here.]
Earlier today, HUD held a conference call for participants of the UPCS-V Demonstration. The call provided an update of what was occurring with the Demonstration and the next steps in the process.
There are 234 agencies that are participating in the UPCS-V Demonstration. Of these, four agencies are currently doing UPCS-V inspections. Fifteen additional agencies are scheduled to begin doing UPCS-V inspections in April 2017. HUD has been gathering feedback from PHAs to improve the usability of the inspection software and has identified 39 items to improve in the software. Additionally, the protocol and decision trees are being updated from feedback from PHAs. HUD has noted that there are a limited number of electronic devices that will be available for the Demonstration and is prioritizing PHAs who need them and do not have them.
During the call, HUD noted two areas where they were looking for additional feedback. First, HUD would like feedback from landlords. They would like to hear from PHAs about landlord groups in their area. They are also looking to conduct a landlord event–possibly a call or a conference. Second, HUD will hold two IT vendor days in Phoenix, AZ and Jacksonville, FL on April 5th and April 7th respectively. They are encouraging PHAs to attend these events with their software vendors so that HUD is able to “facilitate a conversation.”
Finally, HUD shared this timeline during the update:
- First PHAs completed inspections of record in January;
- UPCS-V 2.0 released;
- Updated software;
- Updated decision trees;
- Expand adoption of UPCS-V to larger number of PHAs;
- In-person and WebEx training;
- Incorporating weekly updates from weekly trainings;
- February – June;
- Increase the number of inspections for statistical valid sample;
- Understanding potential challenges for PHAs;
- Release of next version of protocol of refinement of decision trees with PHA input;
- Continuous software user experience;
- IT Vendor Day;
- June – January (2018);
- Working towards a full online training tool; and
- Continue training PHAs and evaluating data collected from the Demonstration.
Any questions or feedback can be given to HUD at OED@hud.gov. In the past, HUD has posted a recording of the call and the accompanying slides on their OED website, within a few weeks.
On Friday, February 24, the White House published a new executive order titled “ENFORCING THE REGULATORY REFORM AGENDA.” The executive order is meant to create a framework to implement and enforce regulatory reform. The order directs agencies to create regulatory reform task forces to evaluate existing regulations to repeal, replace, or modify.
The executive order has six sections. A brief summary of each section follows.
Section 1 – Sets the policy of the United States to “alleviate unnecessary regulatory burdens.”
Section 2 – The head of each agency (except those receiving waivers) must designate a Regulatory Reform Officer (RRO) within 60 days of publication of the order. The RRO is to oversee the implementation of the regulatory reform agenda and report to the agency head.
Section 3 – Each agency is instructed to create a regulatory reform task force with an RRO serving to chair each task force, unless another official is designated by the agency head. Entities staffed by multiple agencies are also required to create regulatory reform task forces. The task forces’ objectives are to evaluate existing regulations and make recommendations to repeal, replace, or modify. They should also seek input from entities affected by the regulation and provide a report to the agency head within 90 days detailing the agency’s progress at implementing the regulatory reform agenda and identifying regulations. At a minimum, the task forces are to identify regulations that fall into the following categories:
- eliminate jobs, or inhibit job creation;
- are outdated, unnecessary, or ineffective;
- impose costs that exceed benefits;
- create a serious inconsistency or interfere with regulatory reform initiatives and policies;
- rely on data or methods that are not publicly available or lack sufficient transparency; and
- derive from past executive orders that have been rescinded or substantially modified.
Section 4 – Each agency is required to measure its performance in performing the tasks outlined in the executive order.
Section 5 – The OMB Director may issue a waiver to those agencies that publish few regulations and must publish which agencies receive waivers.
Section 6 – Miscellaneous provisions ensuring that the order does not have unintended adverse effects.
NAHRO commends the administration’s goals to streamline those regulations that are outdated, unnecessary, ineffective, or impose costs that exceed benefits and looks forward to working with HUD’s regulatory reform task force to achieve these goals.
The full order can be read here.
HUD has published its Administrative Fee Rates for Calendar Year (CY) 2017. The administrative fees are paid on the basis of units leased on the first of each month as taken from the Voucher Management System (VMS). There are two fee rates: the Column A fee rate applies to the first 7200 unit months leased in CY 2017, while the Column B fee rate applies to all remaining unit months leased in CY 2017. In cases where the CY 2017 fee rates were lower than those provided CY 2016, PHAs will continue to receive CY 2016 rates. PHAs that have been receiving blended fee rates will continue to receive blended fee rates. PHAs that are eligible and wish to receive blended fee rates, can send their request to the Financial Management Division at HUD. Instructions for applying will be detailed in the 2017 Housing Choice Voucher funding implementation notice.
The CY 2017 Administrative Fee Rates Description can be found here.
The CY 2017 Administrative Fee Rate Table can be found here.
(2/14/17 Edit – the link to the “CY 2017 Administrative Fee Rate Table” pointed to last year’s rates. It has been updated to point to the correct CY 2017 rates.)
According to a HUD official, HUD has updated the Housing Choice Voucher (HCV) Program forecasting tool. The updated tool now includes updated information, including a higher inflation renewal factor; a default forecasting HAP proration of 94% for year 2–i.e., 2017–but the proration can be changed depending on scenarios that the user would like to test; and the ability to forecast up until a fourth year. To access the tool, the user needs to log in through WASS.
Additional information about accessing the tool can be found here.