Author: Tushar Gurjal

HUD to Host MTW Listening Sessions

~ Tushar Gurjal ~ Leave a comment

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

~ Tushar Gurjal ~ Leave a comment

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

~ Tushar Gurjal ~ Leave a comment

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

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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

~ Tushar Gurjal ~ Leave a comment

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.

 

HUD Sends Supplementary Email to 2017 HCV Program Renewal Funding Letter

~ Tushar Gurjal ~ Leave a comment

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.

HUD Sends 2017 HCV Program Renewal Funding Letter

~ Tushar Gurjal ~ Leave a comment

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.

UPCS-V Quarterly Conference Call Posted

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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.

HUD Publishes PIH Notice on Limiting Payments to Influence Federal Transactions, Anti-Lobbying, and Disclosure Requirements

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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.

Senate Confirms Dr. Ben Carson as HUD Secretary

~ Tushar Gurjal ~ 2 Comments

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.]