Affordable Housing

Another Round of Mainstream Vouchers Awarded

~ Tushar Gurjal ~ Leave a comment

Yesterday, HUD awarded another $131.3 million in Mainstream vouchers to 325 PHAs across the country. Mainstream vouchers provide federal rental assistance to non-elderly people with disabilities. In HUD’s press release, Secretary Carson notes that “[t]he [Mainstream voucher] funding announced today allows our local partners to continue helping residents with disabilities live independently.”

The Department’s press release can be found here.

A list of PHAs who received an award this round can be found here.

HUD to Publish 2020 OCAFs and Regulatory Request for Information

~ Tushar Gurjal ~ Leave a comment

Tomorrow, HUD will publish in the Federal Register two notices. The first states the new Operating Cost Adjustment Factors (OCAFs) for 2020. The second asks for help in identifying laws, regulations, and guidelines across various levels of government that artificially raise the costs of affordable-housing development.

  • Notice of Certain Operating Cost Adjustment Factors for 2020 – This notice establishes the OCAFs for 2020. They are applicable on February 11, 2020. Operating Cost Adjustment Factors are used to adjust Section 8 rents for certain project-based contracts. (These are different than renewal funding inflation factors [RFIFs] which are–in general–applicable to a different Section 8 program–the Housing Choice Voucher program.)
  • White House Council on Eliminating Regulatory Barriers to Affordable Housing; Request for Information – This notice seeks to identify “Federal, State, local, and Tribal laws, regulations, and administrative practices that artificially raise the costs of affordable-housing development and contribute to shortages in housing supply.” While it notes that some regulations are useful and provide a benefit, it seeks information on those rules where the costs outweigh the benefits. The notice seeks “data, other information, analyses, and recommendations on methods for reducing these regulatory barriers.” Comments will be due in 60 days from the date of publication (tomorrow).

The pre-publication copy of the OCAFs can be found here.

The pre-publication copy of the request for information on regulatory barriers to developing affordable housing notice can be found here.

ACC Revisions Released

~ Eric Oberdorfer ~ Leave a comment

On November 8, HUD will issue a 30-Day Notice of Proposed Information Collection on the Public Housing Annual Contributions Contract (ACC) for Capital and Operating Grant Funds in the Federal Register. HUD previously published a 60-Day Notice of Proposed Information Collection for the ACC in December, 2018. NAHRO has noted to HUD that it does not believe revising the ACC through the Paperwork Reduction Act (PRA) is appropriate, as it is a unilateral approach. Although HUD is required to respond to comments through the PRA, there is no requirement to accept those comments or negotiate further with affected partners.  

Although NAHRO believes that the ACC has been and continues to be a contract between a PHA and the federal government, HUD disagrees and views the ACC as a grant agreement. In light of this, HUD proposes changing the name of the Annual Contributions Contract to the Annual Contributions Terms and Conditions, while still referring to the document as the ACC. 

HUD’s most recent version of the ACC removes numerous definitions and requirements that were included in the prior version of the ACC released last December. This includes deleting: 

  • Addition of the term “program receipts”; 
  • A requirement for PHAs to follow HUD-issued notices and HUD-required forms or agreements; 
  • A Prohibition on PHAs from releasing any information contained in HUD’s system of records (SORN) without prior HUD approval 

HUD notes that these requirements are already defined and included in existing regulations, and as such do not need to be included in the ACC.

The 30-Day version also removes mixed-finance specific language from the ACC. Mixed-finance provisions will now be included as amendments to the ACC. 

Lastly, the latest proposed ACC includes an additional section on remedies. The section notes that the agreement does not contemplate money damages as a remedy for a breach of the agreement by HUD. 

In their response to comments from the 60- Day Notice of Proposed Comments, HUD provides additional clarification for what the ACC will not impact. This includes language clarifying that MTW Standard Agreements will not be impacted by changes to the ACC, PHAs may make requests to HUD to amend the ACC, and that changes to the ACC are not intended to address any future changes to Central Office Cost Centers (COCCs), including HUD’s proposal to re-federalize dollars within COCCs. 

2019 FUP NOFA Released

~ Tushar Gurjal ~ Leave a comment

10/25/2019 edit – correct application due date added.

The Department has released the 2019 Family Unification Program Notice of Funding Availability (i.e., the 2019 FUP NOFA). The NOFA makes available $20 million in funding. Applications are due by December 17, 2019. The Department expects to make approximately 40 awards from this NOFA.

The Family Unification Program serves two categories of people. The first is families for whom the lack of adequate housing is a primary factor in the imminent placement of the family’s child in out-of-home care or the delay in the discharge of the child to the family in out-of-home care. The second category is composed of youth at least 18 years and not more than 24 years of age who left foster care (or will leave foster care within 90 days) and are homeless or are at risk of becoming homeless at age 16 or older.

In addition to meeting certain threshold criteria, HUD will be using rating factors in deciding how to allocate FUP funding. In making its decisions, HUD will also look at a PHA’s past performance in managing funds and assess a PHA’s risk (e.g., financial stability, quality of management, history of performance, etc.). Additionally, the Department will look at the following seven rating factors:

  1. Housing search assistance in low-poverty census tracts (16 points) – Points awarded if the PHA, Public Child Welfare Agency (PWCA), or Continuum of Care (CoC) provides, funds, or makes available housing search assistance in low-poverty census tracts;
  2. Financial Assistance (18 points) – Points awarded if the PHA, PCWA, or CoC provide, fund, or otherwise makes available financial assistance to assist FUP-eligible families and youths;
  3. Previous Coordination (6 points) – Points awarded if the PHA or the PCWA can demonstrate recent cross-program coordination with a local CoC;
  4. Post-move counseling (14 points) – Points awarded if the PHA, PCWA, or CoC provides funds, or otherwise makes available post-move counseling to FUP-eligible families or FUP-eligible youth;
  5. Case management to FUP families (16 points) – Points awarded if case management to FUP families will be made available after they have been issued a voucher. These families may not be forced to participate in these services;
  6. Self-sufficiency Programs (12 points) – Points awarded if the PHA administers the HUD Family Self-Sufficiency program, or similar program promoting self-sufficiency, that is active at the time of application; and
  7. Supportive Assistance for Youth to 36 months (18 points) – Points awarded if the services required to be provided to FUP-eligible youth as identified in the Memorandum of Understanding will be provided beyond 18 months.

The Frequently Asked Questions document on the NOFA can be found here.

The 2019 FUP NOFA can be found here.

HUD Updates HCV Two-Year Projection Tool with 2020 Estimated Inflation Factors for PHAs

~ Tushar Gurjal ~ Leave a comment

I received word from a HUD official that the Housing Choice Voucher (HCV) Two-Year Tool has been updated with estimated PHA-specific inflation factors. The Two-Year Tool allows those folks managing voucher programs to “analyze a PHA’s utilization situation which includes running basic leasing and spending scenarios to better inform decisions . . . to optimize the program over a multi-year period.” After each yearly funding cycle, HUD applies an inflation factor to the amount spent on vouchers in the previous year to arrive at the PHA’s renewal funding for the upcoming year. This inflation factor is specific to the PHA. The Two-Year Tool has now incorporated estimates of each PHA’s inflation factor to assist in planning for the upcoming year.

The Two-Year Tool can be found here.

2020 Operating Fund Inventory Validation Revised Dates

~ Eric Oberdorfer ~ Leave a comment

HUD sent out an email on October 17 informing PHAs that HUD has revised the timeline for the Operating Fund Inventory Validation process for the funding year 2020. HUD plans to publish the inventory of projects for PHA review on October 31, 2019 to the 2020 Operating Fund Processing web page.

PHAs should review their inventory and contact their local Field Office to identify any corrections by November 5, 2019.  This includes projects that should be added or removed to the inventory for Operating Funds in 2020. Requests for funding for projects that are new and were not funded in 2019, should be sent in a separate communication to your local Field Office.

Additional information can be found here.

 

Money Available for Carbon Monoxide Detectors

~ Tushar Gurjal ~ Leave a comment

The Department of Housing and Urban Development sent an email to Executive Directors reminding them that $5 million is available for PHAs for the purchase, installation, replacement, and repair of carbon monoxide detectors. Applications for this funding are due by 5 pm ET on Friday, October 25, 2019.

Additional information can be found here.

DHS Public Charge Rule Implementation Stopped

~ Georgi Banna ~ Leave a comment

A preliminary injunction stopping the implementation of the Department of Homeland Security’s Public Charge Rule has been issued by a judge from US District Court in Manhattan, New York. This means that the Public Charge Rule will not take effect on Tuesday, October 15, 2019, as stated in the rule.

The NAHRO team will continue to follow the Public Charge Rule and the circumstances of its implementation.

FY 2019 FSS Renewal Funding NOFA and FAQ Released

~ Eric Oberdorfer ~ Leave a comment

On September 26, HUD released the FY19 Renewal NOFA for the Family Self-Sufficiency Program. The application package can be found on grants.gov. The deadline for applications is October 28. HUD recommends that applicants check that their grants.gov, DUNS, and SAM registration and passwords are up to date now, so that all agencies eligible for renewal funding can proceed through the application smoothly.

HUD also recently released an FY19 FSS Renewal NOFA FAQ. The FAQ does not replace or supersede the FY19 FSS Renewal NOFA, but provides applicants with answers to frequently asked questions. The FAQ can be found here.

Complimentary Webinar!! 2020 Census & PHAs – October 1, 2pm EDT

~ Georgi Banna ~ Leave a comment

On Tuesday, October 1, at 2pm eastern time, NAHRO will be hosting a complimentary webinar in preparation for the 2020 Census. Below is information on the session and the registration link. This session is for agencies of all sizes from the smallest to the largest and will discuss the 2020 Census and the interaction between Census and PHAs including first-hand PHA experiences.

2020 Census Key Partnership – Public Housing Authorities

The 2020 Census is right around the corner. The U.S. Census Bureau and Public Housing Authorities are working together to make sure every person will be counted. During this webinar you will hear from Carol Gore of the Cook Inlet (Alaska) Housing Authority and John Mahon of the Bayonne (New Jersey) Housing Authority. Carol and John will share their experiences working with the U.S. Census Bureau in addition to employment opportunities for PHA residents. Join us and bring all your 2020 Census questions!

Please register for 2020 Census Key Partnership – Public Housing Authorities on Oct 1, 2019 2:00 PM EDT at:

 https://attendee.gotowebinar.com/register/7438435157680047371?source=blog

After registering, you will receive a confirmation email containing information about joining the webinar.