New Small Area FMR Dashboard

On July 6, HUD sent an email to Executive Directors announcing the posting of a new Small Area Fair Market Rent (FMR) dashboard. The Dashboard lists PHAs that have either adopted the use of Small Area FMRs or the use of an exception payment standard that allows a PHA to raise its payment standard up to 110% of the small area FMR. The dashboard also lists the number of units under small area FMRs, the number of PHAs that use small area FMRs or exception payment standards that can be raised up to 110% of small area FMRs, and the total number of units categorized by Small Area FMR type.

Additionally, the website containing the dashboard also contains links to resources about Small Area FMRs.

The website can be found here.

Continuum of Care and Youth Homeless Demonstration Program 2023 NOFO Released

On July 5, HUD published a Notice of Funding Opportunity (NOFO) for fiscal year 2023 Continuum of Care (CoC) Competition and renewal or replacement of Youth Homeless Demonstration Program (YHDP) grants. More than $3.1 billion is available in total for state and local governments, nonprofits, PHAs and tribal entities. Award amounts will range from grantee to grantee with a minimum award amount of $2,500 to a maximum amount of $15 million.

HUD will prioritize funding for CoCs that have demonstrated the capacity to reallocate
funding from lower to higher performing projects. Project applications for YHDP renewal and replacement must be completed in full and in accordance with the application processes outlined in the NOFO.

The application deadline for this NOFO is September 28, 2023, no later than 8 p.m. ET. The application can be found on grants.gov to apply and the full NOFO can be found here.

For more information on the NOFO, please see our next edition of The NAHRO Monitor on July 18th.

Public Housing Operating Fund Shortfall Notice Published

Shortfall applications due August 7, 2023

On July 7, HUD published PIH Notice 2023-18, “Implementation of Public Housing Operating Fund Shortfall Funding from Federal Fiscal Year (FFY) 2023 Appropriations.” This notice updates PIH Notice 2022-17 with requirements relevant to the $25 million provided under the 2023 Consolidated Appropriations Act. These changes include agencies with shortfall grants from multiple years, budget submission requirements, budget approval processes, and grant restrictions based on specific MTW flexibilities. All PHAs with public housing—including MTW agencies—may apply.

HTF Allocation Notice Released for 2023

On July 11, HUD published allocation information for Housing Trust Fund (HTF) grantees. The notice lists the formula allocation amounts for each eligible HTF grantee–this covers all 50 states, the District of Columbia, Puerto Rico, Guam, the Northern Mariana Islands, and the United States Virgin Islands.

In total, more than $382 million has been allocated for HTF grantees. For the full list please see below:

GranteeFY 2023 allocation
1. Alabama$3,468,011.94
2. Alaska3,066,413.23
3. Arizona6,176,374.12
4. Arkansas3,000,537.12
5. California62,249,056.21
6. Colorado5,587,889.02
7. Connecticut4,510,424.81
8. Delaware3,066,413.21
9. District of Columbia3,066,413.21
10. Florida18,860,872.74
11. Georgia9,289,519.74
12. Hawaii3,066,413.47
13. Idaho3,066,413.21
14. Illinois14,528,243.51
15. Indiana5,391,554.02
16. Iowa3,066,413.85
17. Kansas3,066,413.77
18. Kentucky3,515,069.07
19. Louisiana4,515,321.38
20. Maine3,066,413.21
21. Maryland5,428,248.81
22. Massachusetts8,664,497.83
23. Michigan8,567,551.32
24. Minnesota4,881,842.62
25. Mississippi3,000.537.07
26. Missouri5,346,517.90
27. Montana3,066,413.21
28. Nebraska3,066,413.24
29. Nevada3,992,364.65
30. New Hampshire3,066,413.21
31. New Jersey12,237,784.01
32. New Mexico3,066,413.39
33. New York34,734,754.63
34. North Carolina9,349,938.86
35. North Dakota3,066,413.21
36. Ohio10,420,277.39
37. Oklahoma3,066,414.20
38. Oregon5,468,941.58
39. Pennsylvania12,081,840.36
40. Rhode Island3,066,413.21
41. South Carolina4,254,877.71
42. South Dakota3,000,536.58
43. Tennessee5,290,023.02
44. Texas22,394,218.80
45. Utah3,066,413.40
46. Vermont3,066,413.21
47. Virginia7,563,731.52
48. Washington8,377,579.86
49. West Virginia3,066,413.21
50. Wisconsin5,527,245.89
51. Wyoming3,066,413.18
52. Puerto Rico2,037,321.90
53. America Samoa0
54. Guam157,106.91
55. Northern Marianas76,533.43
56. Virgin Islands152,726.78
Total$382,361,726.94

Learn More About the EPA’s Solar for All Grant Program at NAHRO’s Summer Symposium

On June 28, the Environmental Protection Agency (EPA) welcomed applications to the $7 billion grant competition Solar for All, which was created by the Inflation Reduction Act’s Greenhouse Gas Reduction Fund (GGRF) to expand existing and implement new residential solar investments in low-income and disadvantaged communities. The program will award up to 60 grants to states, territories, Tribal governments, municipalities, and eligible nonprofits.

NAHRO’s Summer Symposium includes a session titled Green Energy Funding in the Inflation Reduction Act and the Bipartisan Infrastructure Act which will include a panelist from the EPA to discuss the NOFO. Register here.

The application deadline for submission is September 26, 2023. In addition, applicants are required to submit a Notice of Intent by the following dates:

  • July 31, 2023, for all states, the District of Columbia and Puerto Rico
  • August 14, 2023, for U.S. territories, municipalities and eligible nonprofits
  • August 28, 2023, for Tribal governments and Intertribal Consortia

PHAs can apply for grant funding individually or as subrecipients in applications. PHAs can also apply through coalition applications with other organizations. The minimum amount to apply for the program is $25 million and recipients must serve a minimum of 10,000 low-income households.  

While PHAs can still participate in awarded programs in which they are not formal partners or subbidders, they must contact the state or regional sponsor applying for the award before September 26.

Seventy-five percent of the grant award must be in the form of “financial assistance” which means grants, loans, subsidies and other direct financial support to offtakers (tenant recipients). There is also a requirement that each offtaker or participant demonstrate a 20% or better reduction in their electricity bill. The other 25% can pay for technical assistance, outreach, marketing support, contractor training, tenant education, interconnection support, and program management.

The application can be found on grants.gov.  

NSPIRE Final Scoring Notice Released 

On July 6, HUD released the “National Standards for the Physical Inspection of Real Estate and Associated Protocols, Scoring Notice” for public inspection. It will be officially published in The Federal Register on July 7, 2023. Public Housing inspections were scheduled to begin July 1, 2023. 

The notice outlines how NSPIRE inspections will be scored and responds to comments submitted in response to the Proposed Scoring Notice. It significantly revises the proposed notice in two ways.  

  1. The final notice eliminates the new letter grade requirement. Now, NSPIRE scores will no longer provide a letter grade categorizing a property’s physical condition based on the inspection score it receives.  
  1. Projects that have one deficiency in multiple parts of a building will only have points deducted once per “inspectable area”—units, inside common areas, and outside areas—but not multiple times per each inspectable area.  

The final notice does not revise the new methodology, which prioritizes resident health and safety by prioritizing units most heavily. Final scores will be calculated by weighting each deficiency the inspection finds. Weights are determined by the location and severity of the deficiency. Those found in units are weighted more heavily than common areas inside buildings, and deficiencies outside of buildings are assigned the lowest weights. At the same time, “life-threatening” deficiencies, as defined by HOTMA, are given the greatest weight and the lowest severity deficiencies are given the lowest. Therefore, a life-threatening deficiency found in a unit will result in the largest possible score deduction of any single deficiency.  

The NSPIRE Administrative Procedures Notice was published on July 3, 2023. For more information, please see the pre-published Final Scoring Notice, NAHRO’s July 3rd NSPIRE coverage, and the forthcoming July 15 edition of The NAHRO Monitor.  

HUD Publishes NSPIRE Administrative Procedures Notice

On July 3, HUD published a notice titled “Implementation of National Standards for the Physical Inspection of Real Estate (NSPIRE) Administrative Procedures” (PIH 2023-16 / H 2023-07). The notice details the process and operational requirements for public housing and multifamily housing assistance programs. It discusses procedures for inspections; submitting evidence for deficiency correction; submitting technical reviews; administrative review; and certain other administrative requirements associated with the implementation of the NSPIRE inspection protocol.

The notice states that the NSPIRE final rule will be implemented in phases. The Department will begin inspections under the new protocol for public housing properties after July 1, 2023. It will prioritize properties that have not been inspected since normal operations resumed after the pandemic in June 2021; PHAs with a fiscal year end of March 30; and troubled PHAs. For housing choice voucher programs (including project-based voucher properties), the NSPIRE final rule will be effective Oct. 1, 2023. For multifamily housing programs, HUD will begin inspections under the new protocol on July 1, 2023 for those who participated in the NSPIRE demonstration, while those who did not will begin on Oct. 1, 2023.

NAHRO will provide our members with additional information about the contents of the notice in the coming days.

The full notice can be found here.

Guidance on SLRs for PBVs

On June 29, HUD published a notice titled “Process for Requesting Subsidy Layering Reviews for Project-Based Vouchers” (PIH Notice 2023-15). When PHAs project-base vouchers in combination with other governmental assistance (i.e., other federal, state, or local funds), the project is required to undergo a subsidy layering review (SLR). This review ensures that projects do not receive excessive compensation. If a project-based voucher (PBV) property is not using other governmental assistance, then no SLR is required.

Depending on the specifics of the project, a PHA may request that HUD or its state Housing Credit Agency (HCA) perform the SLR. The notice details the procedures for a PHA to request which entity perform the SLR in certain instances. The HCA’s participation is voluntary and it may charge a reasonable fee. The PHA has discretion on whether to use its administrative fees for this HCA fee.

  • PHA requests that HUD perform the SLR – a PHA may request that HUD perform the SLR whether a project does or does not contain a low-income housing tax credit (LIHTC). The PHA must communicate, in writing, to the HUD field office that they would like HUD to perform the SLR. The request can be stated as “AB123 would like HUD HQ to perform the SLR.
  • PHA requests that the participating HCA perform the SLR – 1) for projects without a LIHTC, the PHA will follow steps detailed in section 4 of the notice, but the memo to the field office will confirm that the PHA requests that the HCA perform the SLR, if the HCA is available for review; 2) for projects with a LIHTC, the PHA sends the request directly to the HCA, but the PHA must notify the field office that it has made the request.

In instances where there is no HCA, the PHA has requested that HUD perform the SLR, or in instances where the HCA will not perform the SLR, the field office public housing representative will submit the appropriate documentation to HUD headquarters for the SLR.

Section 4 of this notice contains a list of steps required for a PHA to request that HUD perform the SLR, including a list of the appropriate documentation.

A list of participating HCAs can be found here.

The full notice can be found here.

EPA Announces NOFO for $7B Grant Program “Solar for All”

On June 28, the Environmental Protection Agency (EPA) welcomed applications to the $7 billion grant competition Solar for All, which was created by the Inflation Reduction Act’s Greenhouse Gas Reduction Fund (GGRF) to expand existing and implement new residential solar investment for low-income and disadvantaged communities. The program will award up to 60 grants to states, territories, Tribal governments, municipalities, and eligible nonprofits.

The application deadline for submission is September 26, 2023. In addition, applicants are required to submit a Notice of Intent to be eligible by the following dates:

  • July 31, 2023 for all states, the District of Columbia and Puerto Rico
  • August 14, 2023 for U.S. territories, municipalities and eligible nonprofits
  • August 28, 2023 for Tribal governments and Intertribal Consortia

There are three award options that include awards for programs that serve a specific state or territory, awards for programs that serve American Indian and Alaska Native communities and awards for programs that serve communities in multiple states. Different sized award amount will be determined by the total number of households served.

The application can found on Grants.gov here.

 

HUD Proposes Changes to FMR Methodology

Last week, HUD’s Office of Policy Development and Research (PD&R) published proposed changes to the methodology used for calculating fair market rents. There are two material changes included to the calculation of FMRs. First, the proposal would include a change in the definition of “recent mover” as used in the recent movement adjustment. HUD is proposing to consider the rents of households who moved into their unit only in the current American Community Survey (ACS) year. Currently, HUD looks at movers in the past 23 months. HUD intends for this change to be more reflective of current market conditions.

The second change would be to retain and expand the use of rent inflation factors calculated by private sector sources. HUD first used this expanded inflation factor while calculating 2023 FMRs. NAHRO encourages HUD to continue using the most robust and up-to-date inflation factors to ensure FMRs are matching the current market.

The notice can be found here. Comments are due July 24.