RAD: Program Updates and PHA Experiences
A NAHRO Professional Development e-Briefing
Tuesday, February 13, 2018
1:30 – 3:00 pm EST
The Rental Assistance Demonstration (RAD) continues to be a critically important tool for housing authorities looking to pursue innovation while renovating and preserving their local affordable housing stock. As we begin 2018, join the NAHRO Policy Team for an in-depth review of the current status of RAD. Participants will also hear from PHAs that have gone through the RAD conversion process. These RAD agencies will discuss why RAD worked for them, explain how they chose between Project Based Vouchers (PBV) or Project Based Rental Assistance (PBRA), and share lessons learned and best practices. Whether your agency is a RAD veteran or exploring whether RAD is a viable option for the future, don’t miss this opportunity to have your questions addressed by industry experts during this interactive online training.
Only $95 for NAHRO members!
Registration closes Monday, February 12 at 11:59 ET pm.
Reminder: Whether you’re watching alone or with an audience of 100, only one registration per connected device is required, making NAHRO Professional Development’s e-Briefings an outstanding value! Can’t attend the session at the scheduled time? Register anyway, and we will email you a link to the archived recording as soon as it’s ready to be stream.
HUD has posted a pre-publication copy of the “Allocations, Common Application, Waivers, and Alternative Requirements for 2017 Disaster Community Development Block Grant Disaster Recovery Grantees” notice. The notice is to be published in the Federal Register and will be applicable five days after being published.
As HUD’s summary states, “This notice allocates $7.39 billion in Community Development Block Grant disaster recovery (CDBG-DR) funds appropriated by the Supplemental Appropriations for Disaster Relief Requirements, 2017, for the purpose of assisting in long-term recovery from 2017 disasters. This notice describes applicable waivers and alternative requirements, relevant statutory provisions for grants provided under this notice, the grant award process, criteria for action plan approval, and eligible disaster recovery activities. Given the extent of damage to housing in the eligible disaster areas and the very limited data at present regarding unmet infrastructure and economic revitalization needs, this notice requires each grantee to primarily consider and address its unmet housing recovery needs.”
Breakdown of the $7.39 billion:
- State of Texas – $5,024,215,000
- State of Florida – $615,922,000
- Commonwealth of Puerto Rico – $1,507,179,000
- United States Virgin Islands – $242,684,000
Congress continues to discuss additional supplemental distaster funding for the 2017 disaster. NAHRO is following these discussions and will share additional information as it becomes known.
On Friday, HUD sent an email announcing a new list of Frequently Asked Questions (FAQ) that responds to the new notice delaying the submission date for the local government Assessment of Fair Housing (AFH). HUD “strongly encourages program participants to visit [the FAQ].” The new notice can be found on the Affirmatively Furthering Fair Housing (AFFH) HUD Exchange webpage.
The FAQ can be found here.
Tomorrow, HUD will publish a notice in the Federal Register titled “Affirmatively Furthering Fair Housing: Extension of Deadline for Submission of Assessment of Fair Housing for Consolidated Plan Participants.” The notice states that for local government consolidated plan participants, the deadline for submitting their Assessment of Fair Housing (AFH) will be extended to the next AFH submission date after October 31, 2020. Although the notice will be effective immediately after publication in the Federal Register, HUD is inviting public comment for 60 days on the extension. [1/5/18 Edit – Comments are due by March 6, 2018.]
The notice extends the deadline for submission of an AFH to all local government consolidated plan program participants to the AFH submission deadline after October 31, 2020. Local governments that qualified for a previous extension under a October 24, 2016 notice are also covered under this extension. All local government program participants must still comply with the statutory obligation of affirmatively furthering fair housing.
Until a consolidated plan program participant is required to submit an AFH, it will continue to provide the AFFH Consolidated plan certification in accordance with requirements that existed prior to August 17, 2015. These requirements obligated a program participant to certify that it would affirmatively further fair housing by conducting an Analysis of Impediments (AI) to fair housing choice within the jurisdiction and take action to overcome the effects of the identified impediments.
For program participants starting a new 3 to 5 year consolidated plan cycle, the AI should continue to be updated until those consolidated plan program participants submit an AFH after October 31, 2020. Program participants that have already submitted an AFH which has been accepted by HUD must continue to execute the goals of that AFH (they are not required to perform an additional AI). Program participants that received a non-accept decision should not submit their revised AFHs. HUD will discontinue the review of AFHs currently under review and will not render an accept, deemed accepted, or non-accept determination.
New Markets Tax Credits (NMTC) help localities build stronger neighborhoods by investing in housing, schools, and other vital projects that are targeted at helping low-income communities. Between 2003 and 2015, $42 billion in direct NMTC authority has generated almost $80 billion in capital for local businesses and revitalization projects. NMTC investment has resulted in the creation or retention of over 750,000 jobs, and the financing of over 178 million square feet (sq. ft.) of commercial real estate and almost 14,000 affordable housing units. NMTCs are a proven and effective tool for generating private-sector investments in communities in need. This is one in a series of articles that show how public housing authorities (PHAs) and community development agencies have successfully used federal tax credits and tax-exempt bonds to build and/or preserve public housing and affordable housing and to increase the sustainability of communities. Continue reading
In order to aid communities and accelerate disaster recovery for those impacted by Hurricanes Harvey, Irma and Maria, HUD has announced a package of 19 regulatory and administrative waivers for the following Community Planning and Development (CPD) programs: The Community Development Block Grant (CDBG) Program, HOME Investment Partnerships (HOME) Program, Housing Opportunities for Persons with AIDS (HOPWA) Program, and Emergency Solutions Grant (ESG) Program.
According to HUD, this waiver package represents the largest collections of regulatory and administrative waivers ever issued by the Department at one time. State and local grantees located in major disaster declared areas can now access a waiver through a new simplified notification process. HUD’s flexibilities include: Continue reading
Today, the HUD Office of Community Planning and Development (CPD) published a new notice (CPD-17-01) that provides guidance on how Emergency Solutions Grants (ESG) Program funds can be sub-awarded to Public Housing Agencies (PHAs) and Local Redevelopment Authorities (LRAs). On July 29, 2016, President Obama signed into law the Housing Opportunity Through Modernization Act of 2016 (HOTMA) which included language, first proposed by NAHRO, that amended the McKinney-Vento Homeless Assistance Act (42 U.S. 11373(C)) to permit local governments receiving ESG funding to sub-award their ESG funds to PHAs and LRAs for eligible ESG activities. This change saves grantees from having to go through a costly and time-consuming procurement process if they wish to devolve their funds to any PHA or LRA. This change became effective upon enactment of HOTMA last year and required no regulatory rulemaking. This new notice provides additional guidance on the allowable sub-awards to PHAs and LRAs and the key requirements (e.g. consistency with the Consolidated Plan) that apply to sub-awarded funds
Last month, President Trump signed H.R. 601 into law, providing $15.25 billion in disaster relief for victims of Hurricane Harvey. Of the amount, $7.4 billion goes to the Federal Emergency Management Agency (FEMA) to help meet immediate needs, and $450 million to the Small Business Administration (SBA) for disaster-relief loans. The remaining $7.4 billion goes to the Department of Housing and Urban Development (HUD) Community Development Block Grant Disaster Recovery (CDBG-DR) program for disaster relief and long-term recovery. This blog will explain what the CDBG-DR program is and how funds will be allocated and administered to disaster impacted communities.
On Tuesday, September 26, HUD sent an email to PHA Executive Directors in Declared Disaster Counties. The email provides information that may be useful for PHAs in those areas.
Federal Emergency Management Agency (FEMA) Public Assistance Program – PHAs in declared disaster areas may be eligible to apply for Stafford Act Section 403 and Section 406 funds through FEMA’s Public Assistance Programs program. The Public Assistance grant program covers emergency work (covered by Section 403; e.g., debris removal, demolition of unsafe structures; or boarding of windows) and permanent work (Section 406), unless Congress appropriates funds to HUD for these purposes. Additional information on this FEMA program can be found here.
FEMA and HUD Data Sharing – Starting the week of September 18, HUD’s Office of Public and Indian Housing (PIH) began sending reports to PHAs about program participants who have registered for FEMA assistance. HUD anticipates continuing to send these reports on a weekly basis or as new information is available. Please use discretion handling the workbooks and data.
Fraud – If PHAs have concerns about fraud, the email lists methods to contact the federal government.
FEMA’s Fraud Hotline – (866) 720-5721 and
HUD OIG’s Fraud page – (800) 347-3753.
Expedited Waiver Process – As mentioned in NAHRO’s previous blog post, HUD is in the process of creating a expedited waiver process for those PHAs in disaster areas. The process will be articulated in an upcoming Federal Register notice. This notice will be modeled on previous expedited waiver process notices.
Additional information on the Hurricanes and HUD’s response can be found at the following links:
On September 19, 2017 at 1:00 PM EDT, HUD will host a webinar titled “Buying Right: CDBG-DR and Procurement A Guide to Recovery,” which will focus on procurement requirements for the Community Development Block Grant (CDBG) Disaster Recovery programs. This webinar will cover the latest procurement guidance under the Office of Management and Budget (OMB) Uniform Guidance as provided in 2 CFR Part 200. This 1.5 hour webinar is designed for all CDBG and CDBG-DR grantees, especially staff charged with purchasing goods and services.
Participants will learn:
- Roadmap of the procurement process
- Procurement methods for different types of goods and services
- Best practices to ensure compliance with the Uniform Guidance requirements
- Common pitfalls in procuring goods and services by grantees
Register for the webinar here.