Affordable Housing

Notice on HCV Financial Reporting Requirements

~ Tushar Gurjal ~ Leave a comment

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.

Continuum of Care Grants Awarded

~ Eric Oberdorfer ~ Leave a comment

HUD has awarded $2.5 billion in Continuum of Care (CoC) grants to support 6,597 local homeless assistance programs across the nation. This funding renews grants for existing programs. Due to the pandemic, grants were renewed through a dramatically streamlined process. HUD’s CoC program supports a broad array of interventions designed to assist individuals and families experiencing homelessness, particularly those living in places not meant for habitation, located in shelter programs, or at imminent risk of experiencing homelessness. HUD’s press release can be found here.

Clean Air For All Webinar on Resident Engagement

~ Eric Oberdorfer ~ Leave a comment

Tomorrow, January 27 from 1-2:00 pm CT, Zoom

Clean Air for All invites you to join us for an upcoming webinar- Working Together: Resident Engagement during (and after) the Pandemic. We will discuss ways to engage residents in a building’s smoke-free policy and cessation efforts, both remotely and in person.

Webinar Objectives
· Highlight successful resident engagement efforts that have occurred at PHAs
· Outline strategies to help PHAs keep residents engaged both in person and remotely
· Describe resources available for resident engagement

Speakers
–    Mr. Georgi Banna, National Association of Housing and Redevelopment Officials
–    Ms. Lorraine Lathen, Jump at the Sun Consultants, Wisconsin African American Tobacco Control Network
–    Mr. Ernest Watts, Robeson County Health Department, North Carolina
–    Kara Skahen, Clean Air for All: The Smoke-Free Public Housing Project

Register here!

HUD Updates Demolition and Disposition Notice

~ Tushar Gurjal ~ Leave a comment

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.

HUD Posts Three Notices

~ Eric Oberdorfer ~ Leave a comment

On January 15, HUD posted three PIH Notices on their website. Notice PIH 2021-04, titled Public Housing Operating Fund (“OpFund”) Grant Eligibility Calculations and Processing for Calendar Year (CY) 2021, provides public housing agencies (PHAs) with instructions for calculating OpFund grants for CY 2021 and establishes submission deadlines. Notice PIH 2021-05, titled Use of Shared Housing in the Housing Choice Voucher (HCV) Program, reminds PHAs that Shared Housing remains a permissible and viable option that
may be made available to HCV participants, and of the specific programmatic requirements related to Shared Housing for the HCV program. Lastly, Notice PIH 2021-06, titled Process for Amending ICDBG-CARES Grants, provide ICDBG-CARES grantees with instructions on how to amend the use of existing Indian Community Development Block Grant (ICDBG) Imminent Threat (IT) funds provided under the CARES Act.

Mobility Demonstration Updates

~ Tushar Gurjal ~ Leave a comment

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.

NAHRO on Instagram Live NOW!

~ Georgi Banna ~ Leave a comment

Join NAHRO’s Director of Congressional Affairs, Tess Hembree; and NAHRO’s Legislative Network Chair & Minneapolis Housing Authority Deputy Director Jennifer Keogh discuss What Does 2021 Mean for Affordable Housing?

They are on Instagram now at https://www.instagram.com/nahronational/. Join the discussion!

This Instagram Live session ended but you can view the recording at https://www.instagram.com/nahronational/channel/.

HUD Releases Revised COVID-19 Waiver Notice

~ Tushar Gurjal ~ Leave a comment

On November 30, HUD released a notice extending COVID-19 waivers for PHAs. This notice is titled “COVID-19 Statutory and Regulatory Waivers and Alternative Requirements for the Public Housing, Housing Choice Voucher (including Mainstream and Mod Rehab), Indian Housing Block Grant and Indian Community Development Block Grant programs, Suspension of Public Housing Assessment System and Section Eight Management Assessment Program, Revision 2” (PIH 2020-33(HA), Rev-2). This notice restates the waivers from previous notices and incorporates the waivers from the mainstream voucher waiver notice and mod. rehab. waiver notice. It also adds several new waivers and alternative requirements and extends most of the waivers until June 30, 2021 (previously, most waivers were set to expire at the end of this year).

Some aspects of the previous waiver notice remain in place. First, the use of these waivers is discretionary. The PHA may choose which waivers it wishes to use. Additionally, some waivers have alternative requirements which should be read carefully. Finally, PHAs must publicly post or otherwise make available a list of all the waivers and alternative requirements the PHA choose to implement. The PHA must also notify residents and owners or the impact of the waivers and alternative requirements.

Members of NAHRO will receive additional information about this notice.

The full notice can be read here.

A quick reference chart of the waivers and their period of availability can be found here.

New HUD Guidance on Remote Hearings and Remote Briefings

~ Tushar Gurjal ~ Leave a comment

The Department has published a notice titled “Guidance for PHAs on the Allowability of Remote Hearings and Remote Briefings” (PIH 2020-32). The notice provides additional guidance for conducting remote hearings (e.g., informal hearings for denial of admission, informal settlement of a grievance, etc.) and remote briefings (e.g., oral briefings for new Housing Choice Voucher [HCV] applicants, project-based voucher applicants, and tenant-protection voucher families). The notice outlines requirements for the technology platform used to conduct these activities remotely, discusses how to identify and resolve technology barriers prior to conducting remote hearings or briefings, discusses presenting documents prior to remote hearings and remote briefings, discusses specific public housing requirements, and specific HCV requirements.

Members of NAHRO will receive additional information on this notice.

The full notice can be found here.

Additional 2020 Capital Funds Distributed

~ Eric Oberdorfer ~ Leave a comment

HUD’s Office of Capital Improvements (OCI) has revised almost all FY 2020 Capital Fund Program (CFP) Formula Grants to distribute an additional $16,846,352 in capital funds. The funding is subject to the original FY 2020 Capital Fund Formula Grant obligation start date of 3/26/2020 with an obligation end date of 3/25/23 and an expenditure end date of 3/25/25. HUD’s list of new Capital Fund Awards can be found here.