COVID-19 CDBG Eviction Moratorium Q&A Released

Earlier today, HUD released a Q&A to address questions concerning the eviction moratorium established by the CARES Act. Section 4024 of the Act imposes a 120-day moratorium on evictions, ending July 24, 2020. The moratorium extends to units in projects receiving funding from Community Development Block Grants (CDBG), Neighborhood Stabilization Programs (NSP) or Disaster Recovery.  

The Q&A clarifies which units are covered by the eviction moratorium, and which fees landlords may charge tenants for accrued costs after the moratorium ends. The full Q&A can be found here. For additional guidance, please visit the CDBG COVID-19 Resources page.  

NAHRO provides additional COVID-19 resources at www.NAHRO.org/coronavirus.

RAD COVID-19 FAQ Updated

In a RADBlast! email earlier today, HUD noted that they have updated one of their COVID-19 FAQs with additional information on RAD conversions during the COVID-19 event. According to the email, this update includes “further guidance on completing environmental reports when professionals may not be able to access the interior or exterior of the site . . . [and] provides an option that would give PHAs more time to execute new Section 8 leases at the point of conversion.”

The updated FAQ may be found here.

[5/21/2020 – edited for clarity.]

HUD PIH Posts May 15th Conference Call with PHAs

Earlier today, HUD’s Office of Public and Indian Housing (PIH) sent an email announcing that it was posting a recording of its conference call with PHAs on May 15th. The call was titled “Navigating PIC and REAC PHAS Reporting and Operational Planning Strategies during the COVID-19 Pandemic.”

Our overview of the call can be found here.

Slides from the call can be found here.

A recording of the call can be found here or below.

Managing During COVID-19: Homelessness Resources Webinar – Wed, May 27 at 2pm ET

On Wednesday, May 27. 2020, NAHRO is hosting a complimentary webinar – Managing During COVID-19: Homelessness Resources.

Join Nan Roman, President and CEO of the National Alliance to End Homelessness, and leaders from NAHRO member agencies for a discussion of available homelessness resources and best practices for their use. Bring your questions and comments and join your fellow PHAs for this interactive webinar!

Register for NAHRO’s Managing During COVID-19: Homelessness Resources Webinar here!

HUD’s Friday Call Review: Changes to PIC and REAC reporting requirements and Remote Video Inspections

On May 15, HUD’s Office of Public and Indian Housing (PIH) hosted a conference call providing updates on changes to PIC and REAC PHAS reporting requirements and operational planning strategies included in the CARES Act.   

Form 50058 Reporting Requirements: HUD will continue to use IMS/PIC to calculate funding allocations and carry out program evaluations and oversight. HUD urges PHAs to submit required Form-50058 transactions in a timely manner to prevent backlog.  

  • The time period for Form-50058 submission has been extended from 60 to 90 days, with the period of availability ending December 31st, 2020. 
  • PHAs that submit their forms during the extended timeframe will see a warning error upon submission, but the forms will be accepted, if there are no fatal errors present. 
  • For new submissions where the PHA does not have a date of previous HQS inspection, enter 01/01/1900. If there has been a date previously entered, use that date instead until a new date is available.  
  • Due to the temporary suspension of Community Service and Self-Sufficiency Requirement (CSSR), PHAs should mark all household members “Pending” unless they are designated as “Exempt.” 

PHAS Scoring: Per PIH Notice 2020-05, REAC is waiving PHAS scoring requirements through the end of the year unless a PHA requests a new PHAS score release. HUD will begin re-scoring with fiscal years ending March 21, 2021, and will notify PHAs 30 days prior to resumption in accordance with local coronavirus restrictions and health protocols.  

EIV Requirements: HUD is waiving Enterprise Income Verification (EIV) requirements through July 31, 2020 in favor of allowing tenants to electronically self-certify with their PHA. However, HUD urges PHAs to download EIV reports during the waiver period, as the data will be overwritten when EIV monitoring requirements resume. HUD reminds PHAs they remain responsible for protecting tenants’ Personally Identifiable Information (PII), and that privacy guidelines will not change in response to the pandemic. 

Remote Video Inspections (RVI): RVIs are HQS inspections conducted via proxy and are intended to provide PHAs additional flexibility to fulfill inspection requirements during the pandemic. As this is a new method of conducting inspections, HUD will follow up with further guidance and a best practices document.  

NAHRO provides additional COVID-19 information at www.nahro.org/coronavirus.

Postponed – NAHRO Presents Webinar on CARES Act Funding and Waivers

UPDATE – The Managing During COVID-19” series: “PHA to PHA Best Practices webinar scheduled for Wednesday, May 20 from 2-3 pm eastern time has been postponed. We apologize for any inconvenience this postponement has caused. Best practices on CARES Act funding and waivers will be discussed in future webinars. Information on future webinars will be posted at www.nahroblog.org. Thanks again.

Tune in this coming Wednesday, May 20, from 2-3 p.m. eastern time for the latest installment of our complimentary Managing During COVID-19” series: “PHA to PHA Best Practices! Your fellow NAHRO members will discuss which waivers they’re using and what they’re spending their funding on. Learn from your peers, ask questions, and share your own ideas!

Click Here to Register for the complimentary webinar Managing During COVID-19: Sharing Best Practices: Waivers and Funding!

Admin Fee Set-aside Application Deadline Extended

Yesterday, HUD sent an email extending the deadline for certain requests related to the administrative fee for the Housing Choice Voucher (HCV) program. The Department will not accept regular mail or faxes for these applications. so PHAs must submit their applications electronically. The extended deadline of 5 pm ET on Wed., July 15, 2020 applies to the following administrative fee requests:

  • Blended administrative fee rate requests (questions may be sent to PIHFinancialManagementDivision@hud.gov);
  • Higher administrative fee rate requests (questions may be sent to FinancialManagementCenter@hud.gov);
  • Special fees (questions may be sent to 2020SpecialFees@hud.gov), including:
    • Category 1: HUD-VASH special fees;
    • Category 2: Family Unification Program special fees;
    • Category 3: Disaster Related Special Fees; and
    • Category 4: Application for other Special Fees under the Secretary’s Discretion.

PIH Notice 2020-04 (a notice implementing the HCV program in calendar year 2020) provides additional details on the eligibility and documentation requirements.

HUD PIH Clarifies CARES Act Funding Timeframe Eligibility and Reporting Requirements

Earlier today, HUD PIH sent an email to PHA Executive Directors clarifying the timeframe around the use of Coronavirus Aid, Relief, and Economic Security Act (CARES Act) funding and clarifying CARES Act reporting requirements. Additional questions regarding the CARES Act may be sent to PIH-COVID@hud.gov.

The text below is taken directly from the email sent by HUD.

Q: What is the start date for use of new public housing funds under the CARES Act? Is it the date of the implementation notice (April 28, 2020), the date they were awarded (May 1, 2020), or the date the CARES Act was passed (March 27, 2020)?

A: 2020 Public housing funds were disbursed for public housing starting May 1, 2020. These funds can cover expenses, including expanded COVID-19 related expenses included in Notice PIH 2020-07, that were incurred starting March 27, 2020. CARES Act obligations should not relate back to a period any earlier than March 27, 2020. 

Q: What is the start date for the use of new HCV Program Administrative Fees awarded under the CARES Act?

A: 2020 HCV Program Administrative Fee funds were disbursed starting May 7, 2020. HCV Administrative Fees can cover expenses, including expanded COVID-19 related expenses included in Notice PIH 2020-08, that were incurred starting March 27, 2020. CARES Act obligations should not relate back to a period any earlier than March 27, 2020. 

Q: My PHA incurred a number of expenses related to COVID-19 prior to the arrival of the CARES Act funds, as our local outbreak started in February. Can these funds cover those expenses? What if we used other funds to cover these expenses– can those accounts be reimbursed?

A: For the public housing program, expenses incurred beginning on March 27, 2020 can be paid for with CARES Act supplemental operating funds, public housing operating funds or public housing capital funds. For the housing choice voucher program, expenses incurred beginning on March 27, 2020 can be paid for with CARES Act funding or FY 2020 administrative fees. If the PHA used other accounts to pay expenses incurred on March 27th or later, they can be reimbursed by the CARES Act funding.

Q: Can you clarify the CARES Act reporting requirements?

A: As described in PIH Notice 2020-07 and PIH Notice 2020-08, the CARES Act requires that recipients of $150,000 or more of CARES Act funding submit certain information regarding the use of CARES Act funds.

This reporting is required for “covered recipients,” defined as any entity that receives covered funds that amount to more than $150,000.  PHAs that receive CARES Act funds that amount to more than $150,000 will be subject to this additional reporting requirement based on the total amounts awarded, not each individual grant award. As outlined in the Office of Management and Budget (OMB) memorandum, M-20-21, existing reporting requirements are anticipated to meet the requirements of Section 15011, but the content and format for this reporting is still under development and will need to be reviewed against current program practices.  The Department will work in coordination with OMB to ensure that this requirement can be fulfilled by recipients of CARES Act funding in a manner that utilizes to the greatest extent possible existing reporting streams, providing the necessary transparency and accountability with minimal additional burden.  If additional reporting is necessary, further guidance will be released by the Department in the near future. 

Chris Campbell Joins NAHRO for the Summer!

Greetings! My name is Chris Campbell, and I’m a Master of Public Policy (MPP) student at the University of Michigan. I’ll be interning remotely with NAHRO’s Policy and Program Development team this summer.  

Before starting graduate school, I worked for the Los Angeles City Council’s Office of the Chief Legislative Analyst, where I staffed the Planning and Land Use Management Committee.  My work with the Committee introduced me to the basic aspects of the nation’s affordable housing shortage, as well as the debate over which strategies can best help families meet their housing costs.  

Everyone needs a place to live – as a lifelong resident of Southern California, I understand the stress high housing costs can place on a family. This isn’t just a West Coast problem, however. Cities and rural areas across the country need more affordable, high-quality homes to promote the health and well-being of their residents, a fact laid bare by the COVID-19 pandemic. The urgency of our nation’s affordable housing shortage will only grow in its aftermath. I look forward to working with NAHRO’s member agencies and HUD this summer to gain more insight into how federal, state and local government can work together to help renters and owners keep a roof over their heads, especially in these unprecedented times.  

I’ll be posting to the NAHRO blog weekly about housing-related policy developments, so stay tuned!  

Mainstream Voucher Allocation Notice Published

Earlier today, HUD published Notice PIH 2020-09 titled “CARES Act Mainstream Funding for Public Housing Authorities (PHAs) Awarded Funding Allocations in the 2017 and 2019 Competitions.” This notice establishes the process for allocating new Mainstream vouchers according to the requirements of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). Mainstream vouchers are vouchers that serve households that include a non-elderly person with disabilities.

Eligible PHAs are those that previously received a Mainstream voucher allocation through either:

A list of those PHAs can be found here (eligible PHAs are those PHAs with entries under the “2017/2018 Awards” column and the “2019 Awards” column).

Eligible PHAs will receive an increase in Mainstream voucher units of thirty percent. If an increase results in a fractional voucher, HUD will round up. Increased budget authority will be calculated based on per unit cost using the most recent data available to HUD for each PHA. A PHA may decline this increased allocation. Administrative funds will be provided in accordance with PIH 2020-04 (a notice implementing the Housing Choice Voucher program in calendar year 2020).

The Department will publish additional guidance on receiving and using extraordinary administrative fees (these fees are not provided in this allocation). Additionally, Mainstream voucher programs will also be eligible for additional CARES act supplemental HAP funding, the distribution of which will be detailed in forthcoming guidance.

The COVID-19-related waivers detailed in PIH Notice 2020-05 are applicable to Mainstream vouchers.

The complete notice can be found here.