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.

HUD to Publish Revised FY 2019 FMRs

(3/14/19 Edit – the official notice has been published in the Federal Register and can be found here.)

Tomorrow, HUD will publish in the Federal Register revised Fair Market Rents (FMRs) for certain jurisdictions, though a pre-publication copy is currently available. In addition to listing the new FMRs, the notice also responds to comments made to the initial Fiscal Year (FY) 2019 FMRs (See NAHRO’s comment letter here).

According to the notice, “[s]everal commenters suggested that HUD should provide additional funding to PHAs who undertake local area surveys.” (While Congress has the power to decide how to allocate money and how much to spend towards individual programs, HUD may request certain levels of funding for particular programs or tasks through its budget request.) The Department responded by stating that “HUD reminds PHAs that paying for local area rent surveys is an eligible expense to be paid from on-going administrative fees or their administrative fee reserve account.”

FMR by Number of Bedrooms in Unit

2019 Fair Market Rent Area

0 BR

1 BR

2 BR

3 BR

4 BR

Boston-Cambridge-Quincy,  MA-NH HMFA

$1,608

$1,801

$2,194

$2,749

$2,966

Burlington-South  Burlington,  VT  MSA

$992

$1,202

$1,544

$2,008

$2,087

Coos County,  OR.

$538

$684

$837

$1,210

$1,394

Curry  County,  OR

$629

$777

$979

$1,416

$1,574

Douglas  County,  OR.

$657

$773

$1,023

$1,479

$1,796

Oakland-Fremont,  CA HMFA

$1,409

$1,706

$2,126

$2,925

$3,587

Portland-Vancouver-Hillsboro,  OR-WA MSA

$1,131

$1,234

$1,441

$2,084

$2,531

San Diego-Carlsbad,  CA MSA

$1,422

$1,590

$2,068

$2,962

$3,632

San Francisco,  CA HMFA

$2,069

$2,561

$3,170

$4,153

$4,392

San Jose-Sunnyvale-Santa  Clara,  CA

$1,952

$2,316

$2,839

$3,829

$4,394

The pre-publication copy of the notice can be found here.

HUD Requests Comments on RAD for PRAC Notice

In an email sent to its RADBlast! email list earlier today, HUD is requesting comments to a new draft Section 4 to be added to the RAD Revised Notice. The new section would allow for the conversion of properties assisted by Section 202 Project Rental Assistance Contracts. The draft section is posted on the Office of Multifamily Housing’s Drafting Table website. Comments are due by March 12, 2019.

Specifically, HUD is seeking comment on the following topic areas:

  • Is this document well organized?
  • Is the guidance set forth in this document clear? Are there sections that are unclear?
  • Are the proposed terms of the Use Agreement reasonable and adequate?
  • Are there unique features of 202 PRACs or the elderly population that the properties serve that HUD has not adequately accounted for in this Notice?
  • The draft Section describes an option to convert to Section 8 Project-Based Rental Assistance (PBRA) or to Project Based Vouchers (PBV) What is the degree of interest in PBV conversions? Please note that while HUD has developed the framework for a process for seamlessly funding a conversion from PRAC to PBRA, funding a conversion from PRAC to PBV is likely to be more complex.
  • Does HUD provide adequate avenues for stakeholders to provide feedback on the direction of the RAD program and, if not, what additional measures for public feedback should HUD consider?

Comments may be submitted to rad2@hud.gov.

The draft section of the notice can be found here.

Deadline for Updating CY ’18 and CY ’17 VMS Data is Feb. 22

Earlier this morning, HUD sent an email to Executive Directors following up on a message sent on Feb. 6, 2019. In this morning’s email, HUD reminds Executive Directors and Section 8 program managers that the deadline for revising CY 2018 and CY 2017 leasing and expense data–and reporting January 2019 leasing and expense data–is tomorrow, February 22, 2019.

HUD Sends Guidance on Mainstream Vouchers

Earlier today, HUD sent an email outlining additional guidance for mainstream vouchers. The Department highlighted several key issues. The notice can be found here. Additional questions to HUD can be sent to MainstreamVouchers@hud.gov.

Administrative fees – the Department noted that HUD would advance administrative fees on 50 percent of newly awarded mainstream vouchers, and would reconcile administrative fees based on actual leasing later this year (i.e., if less than 50 percent of the vouchers are used, HUD will lower future administrative fee payments by the excess amount awarded). If a PHA awards more than 50 percent of its allocation, it can contact its financial analyst for the additional administrative fee.

Character of mainstream vouchers and new admissions – HUD clarified that mainstream vouchers are regular housing choice vouchers with special eligibility criteria and that awarded vouchers are for new admissions. With respect to the former clause, mainstream vouchers should be treated as regular voucher assistance and program participants should not be treated differently than program participants in the regular housing choice voucher program. Additionally, PHAs must lease awarded vouchers by pulling mainstream-eligible applicants from the waiting list. Housing agencies may not reassign existing participants to the mainstream program to “free up” regular housing choice vouchers.

Waiting list administration – PHAs must maintain one waiting list for all tenant-based assistance, including mainstream voucher assistance. See 24 CFR 982.204(f). In applying for the notice of funding availability (NOFA), if your PHA claimed points for a preference, then it must adopt the preference for one of the targeted groups served by mainstream vouchers. Housing agencies may limit the number of people who will qualify for a preference. See 24 CFR 982.207(a)(3). Housing agencies may adopt criteria defining which families may apply for assistance when opening their waiting lists (PHAs must comply with requirements to provide public notice and accept applications from families for whom the wait list has been opened). See 24 CFR 982.206(b)(1). Housing agencies must have written policies for how preferences will be applied (either first-come, first-served or by random selection). See 24 CFR 982.207(c). Finally, housing agencies may do a full waiting list update or a limited update.

The full notice can be found 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.

VMS Open for CY 2018

Earlier today, HUD sent an email informing Executive Directors the Voucher Management System (VMS) for the Housing Choice Voucher (HCV) program is open for calendar year (CY) 2018. It is also open to for the purpose of updating CY 2017 leasing and expenses. The deadline for revising CY 2018 and CY 2017 VMS data is February 22, 2019.  Additionally, January 2019 VMS submissions are due on February 22, 2019. In the event that the government shuts down on February 15th (if the current continuing resolution is not extended or a budget is not adopted), HUD will grant up to 10 days in extension following the resumption of funding.

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.

TAC Hosting Peer-to-Peer Call on Mainstream Vouchers

On Wednesday February 6th from 1:00 – 2:00 p.m. ET, the Technical Assistance Collaborative (TAC) is facilitating a peer-to-peer call with PHAs awarded Mainstream Vouchers in September 2018. The call will provide PHAs an opportunity to share implementation challenges, how these are being addressed and to identify any technical assistance needs. NAHRO staff will participate. HUD has been invited and we hope they will be able to participate.

Registration for this call is necessary and can be at the link below

https://attendee.gotowebinar.com/register/8531936849390618625

After registering, you will receive a confirmation email containing information about joining the webinar. There is no cost to register or participate in this call.

In Spring 2018, TAC conducted a series of outreach webinars to create interest in the Mainstream funding and to facilitate local partnerships. Over 1,200 PHAs and homeless and disability organizations participated in four outreach webainrs.  Polling of PHAs participating in the webinars indicated that only 25% believed working with their service partners would be challenging but more than 50% of PHAs indicated that identifying units, ensuring move-in resources and assistance was available and ensuring long term tenancy supports are available as needed would be very challenging.

In areas with strong rental markets and low vacancy rates, HCV participants find it difficult to lease up.  The Joint Center’s 2018 State of the Nation’s Housing, found that rental markets remain extremely tight at the lower end; for these units, vacancy rates remain lower than in any year since 2001.   Unfortunately, many participants including elders and people with disabilities need to find housing in these markets – where medical and other services as well as public transportation are available.  Success leasing up is particularly challenging for those who have poor tenancy or criminal records.   Through this and subsequent peer-to-peer calls, TAC hopes to provide technical assistance for PHAs and their service partners as they face these implementation challenges.