Mainstream Voucher FY 2019 NOFA FAQ Updated

Yesterday, HUD updated its Frequently Asked Questions (FAQ) document on the fiscal year (FY) 2019 Notice of Funding Availability (NOFA) for mainstream vouchers.

The FY 2019 NOFA would make an additional $150 million available for mainstream vouchers (a previous NOFA allocated $98 million). The application deadline for this additional round of funding is September 5, 2019.

The updated FAQ can be found here.

The Department’s Mainstream Voucher page can be found here.

[Edit: Some of the links above were corrected to point to the correct documents or websites and the correct deadline has been added.]

New Notice allows PHAs to use Tenant Protection Vouchers for Youth Aging out of Foster Care

In late July, HUD published a notice titled “Tenant Protection Vouchers for Foster Youth to Independence Initiative” [PIH 2019-20 (HA)]. This notice would allow PHAs that do not have a Family Unification Program (FUP), but that have a Housing Choice Voucher (HCV) Program, to request a tenant protection voucher to house a FUP-eligible youth.

Public Housing Agencies must receive a referral from a partnering Public Child Welfare Agency (PCWA) to request the tenant protection voucher. While not required, HUD strongly encourages participation of a Continuum of Care (CoC). Requests may be as small as one voucher up to 25 vouchers per PHA for a fiscal year. The funding for this initiative is not from the Family Unification Program account, but from the tenant protection voucher account and is subject to the availability of funding in that account. These vouchers sunset after being used and are not to be project-based.

  • PHA Eligibility Requirements:
    • PHA must have an HCV Program;
    • PHA must not administer the Family Unification Program (FUP);
    • PHA must amend its administrative plan;
    • PHA must accept FUP-eligible youth;
      • FUP-eligible youth: Youth that have met the following criteria:
        • Attained at least 18 years of age and not more than 24 years of age;
        • Left foster care, or will leave foster care, within 90 days; and
        • Are homeless or are at risk of being homeless;
    • PHA must determine eligibility;
    • PHA must have a partnership with a Public Child Welfare Agency (PCWA);
      • PCWA Roles and Responsibilities:
        • Must identify FUP-eligible youth;
        • Must have a system of prioritization;
        • Must provide written certification to PHA that youth is FUP-eligible; and
        • Must provide supportive services, including:
          • Basic life skills information (money management; meal preparation; and access to health care, etc.);
          • Counseling on compliance with rental lease requirements of the HCV program;
          • Providing reasonable assurances to rental property owners;
          • Job counseling; and
          • Educational and career advancement counseling;
      • PCWA Partnership Agreement (May take the form of a memorandum of understanding or letters of intent):
        • Must define FUP-eligible youth;
        • Must list supportive services and provide them for 36 months;
        • Must address PHA responsibilities;
        • Must address PCWA responsibilities; and
        • Must address Continuum of Care–if involved–responsibilities, including:
          • Integrating the referral process into the CoC’s coordinated entry process;
          • Identifying services; and
          • Making referrals of FUP-eligible youth to PCWAs.

The full notice may be found here.

House Approves Two-Year Budget Deal, Senate Vote Next Week

Congress last night moved closer to finalizing a budget deal that would raise spending caps for FY 2020 and FY 2021 and suspend the debt ceiling until July 31, 2021. The deal raises domestic spending by $27 billion in FY 2020, which is a sizable increase, though less than the $88 billion sought by the House.

The bill was approved by the House by 284-149 and now goes to the Senate, which will vote next week. The President has expressed support for the deal and is expected to sign it.

This finally draws a close to one of the more short-sighted policies enacted by Congress in recent history: the Budget Control Act (BCA). Passed in the summer of 2011, the BCA was a complex attempt to deal with the nation’s debt by requiring Congress to form a “super committee” to cut spending by $1.2 trillion dollars. The failure of the super committee resulted in across the board spending cuts and the implementation of arbitrary, low spending limits through FY 2021. However, the spending limits were only adhered to for a couple years and Congress has since approved budget deals to increase spending beyond the caps.

What’s Next

The Senate has a lot of work to do to catch up to the House. This spring House appropriators passed 10 of 12 appropriations bills at $88 billion higher than current levels for both domestic and defense programs, despite the lack of agreement with the Senate.

One of the approved bills is a robust Transportation-HUD spending bill, details of which are available here (NAHRO members only).

The Senate chose not to begin appropriations work until a final deal is in place and they are expected to stay in Washington during the August recess to begin consideration of bills.

At this point it isn’t clear what path Congress is likely to take to finalize FY 2020, though there have been discussions of trying to move small packages of negotiated spending bills in September, similar to the strategy employed in the fall of FY 2019. There is a high likelihood that a continuing resolution will needed for at least part of the new fiscal year, as floor time in September is limited.

Long-Term Impact

The two-year deal allows for $27 billion in additional spending in FY 2020, but only increases spending by $2 billion in FY 2021. This will pose a challenge for appropriators as the year to year cost increases of programs are typically higher than $2 billion. In FY 2020, it’s estimated that the cost of rental assistance programs at HUD will increase by $1 billion. This cost increase is compounded by lowered FHA contributions to the THUD budget.

Advocacy

Your advocacy will be critical to ensuring that THUD is a high priority for lawmakers- download the new NAHRO Advocacy App (members-only) and watch for news on how to participate in NAHRO’s August Advocacy campaign.

NAHRO Submits Comment Letters on Mixed-Immigration-Status rule and FMR Methodology

Mixed Immigration Status Proposed Rule

On July 5, NAHRO submitted comments on HUD’s proposed immigration rule. The proposed rule, if implemented, would terminate federal housing assistance for families with mixed-immigration-statuses.

The National Association of Housing and Redevelopment Officials believes that the current verification of eligible status system should be left in place. The changes in the proposed rule would unnecessarily hurt families and children, including U.S. citizens, and add additional administrative burden, all without the commensurate benefits suggested in the proposal. The current subsidy proration policy decouples the size of the family from the federal benefit received. This policy has been in place for over two decades and providers of assisted housing, particularly those most impacted by this proposal that serve many mixed-status families, have not vocalized any hardships or desire to change the policy.

In its comment letter to HUD, NAHRO offers the following recommendations:

  1. Make no changes to the current eligible status verification regulations;
  2. If unwilling to follow the first recommendation, then restrict application of the new rule to new applicants of covered programs; and
  3. If unwilling to follow either of the first two recommendations, then take the steps and adopt the recommended language in NAHRO’s comment letter before implementing the proposed rule.

The Department will still be accepting comments until end of the day, July 9th. We encourage all of our members to submit comments in opposition to this rule. We also urge members to use their own language in writing comments, so that they are not automatically screened out before being read. Comments may be submitted here.

The National Association of Housing and Redevelopment Official’s full comment letter can be found here.

FMR Methodology Changes

On July 5, NAHRO submitted comments on HUD’s proposed changes in how it calculates FMRs. The National Association of Housing and Redevelopment Official’s comment letter can be found here.

HCV Funding Implementation Webcast Published

Yesterday, HUD’s Financial Management Division (FMD) published a webcast on the notice titled “Implementation of Federal FY19 Funding Provisions for the Housing Choice Voucher.” The notice was published in April, and NAHRO previously mentioned it on this blog.

The webcast published on YouTube can be found here.

PowerPoint slides from the webcast can be found here.

HUD Publishes HCV FY 2019 Funding Provisions Notice

Last week, HUD published a notice titled “Implementation of the Federal Fiscal Year (FFY) 2019 Funding Provisions for the Housing Choice Voucher Program“; PIH 2019-08. This notice implements the funding provisions of the Housing Choice Voucher (HCV) program in the Fiscal Year (FY) 2019 budget.

The budget includes the following HCV-related amounts:

  • Housing Assistance Payment (HAP) Renewal Funding – $20,313 million;
  • Tenant Protection Vouchers (TPVs) – $85 million;
  • Administrative Fees – $1,886 million;
  • Mainstream Program – $225 million;
  • Tribal HUD-VASH Renewals – $4 million;
  • New HUD-VASH vouchers – $40 million;
  • New Family Unification Program (FUP) vouchers – $20 million;
  • Mobility Demonstration – $25 million; and
  • Total HCV Appropriations – $22,598 million.

Points of Interest:

  • Offset – HUD will perform a “small offset” to ensure that the national HAP proration is at or above 99.5 percent. Detailed calculations of the offsets will be provided to PHAs in the renewal allocation enclosure. Offsets will come from “excess” program reserves.
  • TPVs – HUD will provide TPVs for vacant units that were occupied within the previous 24 months of certain public housing and multifamily housing actions and are no longer available as assisted housing (subject to availability of funds).
  • Blended and Higher Admin. Fees – Applications for blended administrative fees (for PHAs serving multiple administrative fee areas) and higher administrative fees (for PHAs that operate over a large geographic area) are due by Friday, May 31.
  • Special Fees – $30 million in funding is available for HCV homeownership fees; special fees for PHAs that administer TPVs in connection with multifamily housing conversion actions; special fees for portability (the receiving PHA will receive 12 months of funding equal to 15 percent of the PHA’s 2019 Column A rate for administrative fees; while HUD supplies these fees automatically, HUD advises PHAs to make sure accurate PIC data is entered by May 15, 2019); special fees for certain audit costs; and special fees for administrative costs related to administering the HUD-VASH program.
  • Mobility Demonstration – the Department will publish a Federal Register notice to implement that mobility demonstration and announce the competition for funding.
  • Set-Aside Funds – $100 million will be reserved for shortfall funds (no due date); unforeseen circumstances (application due date May 31, 2019); portability (application due date May 31, 2019); project-based vouchers held from use during re-benchmarking (application due date May 31, 2019); and certain instances of HUD-VASH voucher usage (application due date May 31, 2019).

The full notice can be found here.

HUD Publishes Notice on Voluntary Conversions

In late March, HUD published a notice titled “Streamlined Voluntary Conversions of Last Remaining Projects of Small Public Housing Agencies” (PIH 2019-05 (HA)). This notice allows PHAs with 250 or fewer Public Housing units to convert them to Section 8 vouchers within the Housing Choice Voucher (HCV) program under a streamlined conversion process. This notice differs from the Rental Assistance Demonstration (RAD) program in several ways, but primarily in that instead of receiving RAD rents (i.e., a combination of public housing capital fund, operating fund, and tenant rent amounts), PHAs would receive full HCVs for their residents after conversion.

For a PHA to normally use the voluntary conversion option, it must conduct a conversion assessment and provide a timeline identifying PHA conversion actions. Under this notice, HUD is using its statutory authority to waive the conversion assessment requirement to make it easier for small PHAs to convert their portfolios. Public Housing Agencies are eligible under this notice if they meet the following requirements:

  • They have a portfolio of 250 or fewer public housing units;
  • They intend to close-out their public housing program; and
  • Conversion will result in the conversion of all public housing units.

If a converting PHA does not administer a Section 8 HCV program, then another PHA with a Section 8 HCV program must be identified to administer the vouchers.

To apply for a conversion, eligible PHAs must submit a conversion plan to HUD through the Inventory Management System / Public and Indian Housing Information Center (IMS/PIC). The conversion plan and application must include a PHA plan referencing the proposed conversion; evidence of resident involvement; evidence of board approval; a plan of future use of involved assets; HUD approval of environmental requirements; an impact analysis of the conversion on the neighborhood(s) (in the form of a narrative statement); a summary of information concerning the relocation plan; close-out information; and another Section 8 HCV program identified to receive vouchers, if the applying PHA does not have a Section 8 HCV program. Additionally, certain other requirements must be met (e.g., civil rights reviews, etc.). The Department must respond within 90 days of the PHA submitting the conversion plan.

The full notice can be found here.

HUD Sends Email Clarifying Admin. Fee Rates and Portability

Earlier today, HUD’s Financial Management Division sent an email responding to questions received from PHAs regarding HUD’s calendar year (CY) 2019 administrative fee rates. The email notes that the CY 2019 administrative fee rates are effective retroactively to January 1st, 2019. The Department will also publish two additional documents:

  1. A document describing how the 2019 rates were calculated; and
  2. A document to serve as guidance on portability billing, which will include an estimated administrative fee proration that will be recommended for portability.

Until those documents are published, HUD recommends that program administrators use 80% as the estimated administrative fee proration and that they continue to consider using the CY 2018 Portability Administrative Fee Rate Description.

These documents can be found at HUD’s Office of Housing Choice Vouchers, which can be accessed here.

Public Housing Operating Fund Payments for March, April, and May Prorated at 88.7%

Earlier today, HUD sent an email to PHA Executive Directors informing them that HUD will make subsidy obligations available in the Line of Credit Control System (LOCCS) for the Public Housing Operating Fund within the next six business days. The payments for the months of March, April, and May will be obligated at a 88.7 percent proration. Although PHAs are being funded for three months, they are required to only draw down funds one month at a time, unless a multiple month withdrawal is approved by a HUD field office.

The funds being obligated are based on an estimate of PHA eligibility. The department believes that it should know actual eligibility, based on PHA submissions, by June at the earliest. As certain developments may be under- or over-funded based on current estimates, in instances where the estimated funding varies from the actual eligibility, the PHA should contact its field office representative. The PHA should also refrain from drawing down overfunded amounts and–if underfunded–should utilize its reserves until it receives its actual eligible funding.

If a development has been fully converted to RAD in 2018, but has still been awarded 2019 Operating Funds, the PHA should advise its field office immediately and not draw down 2019 funds.

The full notice can be found here.

HUD Sends Additional Information About PH and HCV Payments

Earlier today, HUD sent an email to Executive Directors with additional information about future payments for the Housing Choice Voucher (HCV) program and the Public Housing (PH) program. The email noted that the federal government was operating under a continuing resolution (CR) until Feb. 15, and provided information for potential future payments, if additional money is not allocated by Congress (either by extending the CR or passing a full budget).

2019 PH and HCV Funding

 

March

April

May

HCV HAP

On time; 99% proration

On time; 99% proration

Awaiting information from HUD

HCV Admin. Fee

On time

On time

Awaiting information from HUD

PH Operating Fund

On time; 88% proration

On time; 88% proration

On time; 88% proration

HCV Funding – The HAP prorations are calculated without applying Renewal Funding Inflation Factors (RFIFs). In some places, the actual HAP required may be greater than the amount disbursed as the HAP calculation is not factoring in rising rental prices. Those PHAs with HUD-held reserves (HHR) will still be able to request additional funding from their reserves, if the HUD amount is not enough to cover the PHA’s HAP needs through April. Additionally, some March and April disbursements may automatically include funding from the PHA’s available HHR, if required to meet the PHA’s HAP requirements. The Department has enough funding for March and April administrative fee payments and will also make HAP and administrative fee disbursements for mainstream vouchers for March and April. Finally, in situations where the availability of HCV or mainstream vouchers is in risk, HUD is planning to provide additional guidance on the use of outside funds for HAP and administrative fees–including modifications to the approval process (note: NAHRO asked HUD for this guidance and to modify the approval process). Questions may be directed to PIH.Financial.Management.Division@hud.gov.

PH Funding – The Department will provide funding based on a conservative estimate of need. As HUD receives data on need, it will update funding eligibility.

The full email can be found here.