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.
Tomorrow, HUD will publish in the Federal Register a proposed rule titled “Housing and Community Development Act of 1980: Verification of Eligible Status.” This proposed rule purports to change how families with mixed immigration statuses receive prorated HUD assistance. Comments are due 60 days after publication.
Current Proration of HUD Assistance
Currently, families with a mixed status may apply for assistance by declaring that each member of the family is 1) a U.S. citizen or eligible non-citizen; or 2) decide not to contend eligible immigration status (and not submit verification documentation) for that member. Family members that declare themselves eligible must provide acceptable evidence of immigration status. Verification is provided through the Systematic Alien Verification for Entitlements (SAVE) system–administered by the Department of Homeland Security (DHS). The system saves the information of noncitizens. Assistance is then prorated such that only citizen-members (or eligible non-citizen-members) of families receive funding (excluding those who do not contend their eligible immigration status).
This proposed rule would make two changes to the current system. First, the proposed rule would require that all family members (except those over the age of 62) have their immigration status verified through SAVE (i.e., family members would no longer have the option to not contend their eligible immigration status). Under most covered programs, those who have not submitted evidence of eligible immigration status will be required to do so at their first regular reexamination.
Second, the proposed rule would specify that individuals that do not have a verified eligible immigration status may not serve as the head of household or spouse–i.e., the holder of the lease.
The pre-publication copy of the proposed rule can be found here.
The published in the Federal Register version can be found here (available 5/10/2019).
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.
Tomorrow, HUD will publish its Fiscal Year (FY) 2019 Renewal Funding Inflation Factors (RFIFs) for the Housing Choice Voucher (HCV) Program. These factors are applied to PHAs’ FY 2018 HCV Housing Assistance Payment (HAP) spending to determine HCV HAP eligibility for FY 2019 (i.e., the inflation factor is applied to how much a PHA spent in the previous year to determine how much it is eligible for this year, assuming Congress has fully funded the HAP account). The national inflation factor is 4 percent, though individual PHAs will have different factors depending on their location. The FY 2019 inflation factor calculation methodology remains the same as FY 2018 methodology.
A pre-publication copy of the notice can be found here.
When published tomorrow (4/17/2019), the full RFIFs can be found here.
Last week, HUD’s Office of Public and Indian Housing sent an email detailing the communication and technical assistance efforts HUD was making to ensure that PHAs understood the range of options that were available to reposition their public housing assets. The following are bullet points quoted directly from the email:
- PIH staff have been making presentations at local and national industry meetings to help PHAs become more aware of their repositioning options.
- PHAs wanting to learn more about their repositioning may ask their local Field Office staff to walk them through the benefits of the various options—always with a focus on how best to address the local needs.
- PIH has set up Repositioning Assistance Panels. Field office staff can reserve time with program experts identified by the Office of Recapitalization, Special Applications Center (SAC), Urban Revitalization Division, and Office of Housing Voucher Programs. These experts can discuss the various repositioning options with a PHA, enabling an informed decision about what strategy would best meet local needs. You can set up a time with a Panel through your local Field Office.
- We have also trained Repositioning Expeditors in most Field Offices. These Expeditors are available to help PHAs with their RAD, voluntary conversion, and demo/dispo applications.
- Understanding that these repositioning options are complex, particularly for small PHAs, the Department is working to provide the following starting late spring:
- Develop training materials, sample documents and other tools that help PHAs consider repositioning strategies and understand available options;
- Provide local training sessions to present available repositioning tools and considerations to address local affordable housing needs;
- Develop an online training platform and training materials to help PHAs and their boards understand repositioning options and HUD requirements; and
- Provide direct technical assistance to small PHAs (operating 250 or less assisted units) in how to start and sustain affordable housing strategies.
NAHRO reminds our members that repositioning is a voluntary process. The Department is providing a range of options, none of which are mandatory. Interested agencies should take actions–or not–based on the needs of their local communities and the households the agencies serve.
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.
As previously mentioned on this blog, HUD will host a webinar on the Moving to Work (MTW) Expansion, Cohort #1 tomorrow at 3 pm ET. Listed below is additional information on the webinar that I received from a HUD official.
MTW Cohort 1
The Department has extended the application timeline for agencies to apply to the Cohort #1 of Moving to Work Demonstration Program. Through this extension notice the Department will select thirty agencies to study MTW flexibility.
Cohort #1 will consist of high-performing agencies that administer 1,000 or fewer HCVs and public housing units combined. The deadline to submit the letter of interest package for Cohort #1 is May 13, 2019.
On Thursday, March 28th the MTW Office will host a webinar on Cohort #1. There is no registration required to join the webinar and the call-in information is below.
Step 1: Dial into the conference.
Dial-in: 1-877-369-5243 or 1-617-668-3633
Access Code: 0604767##
Need an international dial-in number?
Step 2: Join the conference on your computer.
Entry Link: http://ems8.intellor.com/login/813201
An email from the folks at the Technical Assistance Collaborative (TAC) informed me that HUD has updated their Frequently Asked Questions (FAQ) document on the Mainstream Voucher Program. It was updated on March 22, 2019. This document is essential reading for all those who have Mainstream Vouchers.
The Mainstream Voucher FAQ can be found here.
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:
- A document describing how the 2019 rates were calculated; and
- 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.
HUD’s Office of Housing Choice Vouchers has posted the calendar year (CY) 2019 administrative fee rates. They can be found here.