In an email sent earlier today, HUD extended the deadline to apply for receiving CARES Act HAP Funding for the Housing Choice Voucher (HCV) program for significant increases in per unit cost (PUC) due to extraordinary circumstances. The deadline has been extended to March 31, 2021 or until all funds have been depleted (currently, $50 million remain).
On October 23, HUD published a notice titled “Implementation of Section 209(b) of the Economic Growth, Regulatory Relief, and Consumer Protection Act (Economic Growth Act)” (PIH 2020-30). This notice implements an energy savings program for small, rural PHAs that was created by the Economic Growth, Regulatory Relief, and Consumer Protection Act (Economic Growth Act). The National Association of Housing and Redevelopment Officials submitted comments on implementing section 209(b). Our comments stated that this program should be distinct from Energy Performance Contracting, that the program should be easy to apply to and to administer, and that PHAs should have flexibility in how they use the savings. We are pleased that HUD closely followed many of NAHRO’s suggestions. The program—called the Small Rural Frozen Rolling Base (SR-FRB)–would allow eligible PHAs to freeze the cost of their energy consumption levels, improve their energy efficiency, and use any cost savings for any eligible public housing purpose at the PHA’s discretion. This program differs from Energy Performance Contracting (EPC) in that it is much easier to apply to and administer.
On October 16, HUD published a notice titled “Guidance for Running an Optimized Housing Choice Voucher Program” (PIH 2020-29). The notice warns of increasing reserves nationally and notes that an optimized Housing Choice Voucher (HCV) program maximizes the number of families served, while minimizing rent burden. The notice discusses several program tools such as the Two-Year Forecasting Tool, the Payment Standard Tool, the HCV Analysis Tool and PIC Drill-Down, and the HCV Guidebook. The notice also discusses the voucher program planning timeline and best practices to increase success rates.
The Department of Housing and Urban Development (HUD) published a rule titled “Housing Opportunity Through Modernization Act of 2016—Housing Choice Voucher (HCV) and Project-Based Voucher Implementation; Additional Streamlining Changes.” This rule does four things. First, it changes regulatory code to implement Housing Opportunity Through Modernization Act of 2016 (HOTMA) provisions that were previously implemented via notice. Second, it proposes to implement additional provisions of HOTMA that have not yet been implemented. Third, it proposes several regulatory changes unrelated to HOTMA. Fourth, the rule proposes removing “obsolete regulatory provisions.” Comments for these proposed changes are due December 7, 2020.
There are several new HOTMA-related topics and non-HOTMA-related topics that this proposed rule is seeking to implement. Among the new HOTMA-related topics that this rule will implement include enforcement of housing quality standards, manufactured home space rental, entering into a project-based voucher (PBV) housing assistance payment (HAP) contract without an agreement to enter a HAP (AHAP) contract, providing rent adjustments using an operating cost adjustment fact (OCAF), owner-maintained site-based waiting lists, and environmental requirements for existing housing. Among the non-HOTMA-related topics touched by this rule are changes that HUD characterizes as clarifying and simplifying the program rules.
Staff at NAHRO are still in the process of reading through the proposed rule. Additional information will be forthcoming.
Earlier today, HUD published a notice titled “Foster Youth to Independence Initiative” (PIH 2020-28). This notice discusses how any PHA which meets certain eligibility requirements (including those agencies that already have a Family Unification Program) may apply for additional Family Unification Program vouchers for youth aging out of foster care. This supply of vouchers is funded through a $10 million set-aside in the 2020 appropriations act.
NAHRO members will receive additional information on this notice.
The Department of Housing and Urban Development (HUD) has published a new chapter–titled “Technology“–as a part of its Housing Choice Voucher (HCV) Landlord Strategy Guidebook for PHAs. The goal of the guidebook is to “share strategies that public housing agencies (PHAs) can implement to improve landlord participation in the HCV program.” This chapter is divided into four sections. The first three sections discuss creating a HCV landlord webpage, creating a HCV landlord portal, and inspections technology. The fourth section is an appendix with information and sample content.
NAHRO members will receive additional information on this newly published chapter.
If a PHA has previously submitted applications for calendar year (CY) 2020 HAP renewal set-aside funding under the “Unforeseen Circumstances” category due to PUC increases caused by COVID-19, the PHA must resubmit according to instructions in this new notice. For those who submitted under the “Unforeseen Circumstances” category for other reasons, they are not required to resubmit, but may do so if their PUC has further increased because of COVID-19.
Public Housing Agencies must meet certain requirements to access this funding. First, applications must be submitted by Oct. 31, 2020. Applications will be reviewed by HUD on a rolling basis. Second, to be eligible, a PHA must have a PUC that is 102 percent or greater than the PUC HUD used to determine the PHA’s CY 2020 renewal funding. The PHA must also meet the submission requirements detailed in the notice.
The PHA will also receive a priority status. If the PHA’s HAP reserves contain an amount that is less than the amount needed to cover 3 months of HAP expenses, the PHA will qualify for priority status. Public housing agencies qualifying for priority status will receive funding shortly after their application is processed, subject to funding availability. Those agencies that receive regular priority will receive notification that their application has been approved, but funding will not be made until November.
Group
Complete Application
PUC > than 102%
HAP Reserve < 3 months
Priority
Eligible for Immediate funding
Yes
Yes
Yes
Regular
To be funded in Nov. 2020
Yes
Yes
No
Ineligible
Ineligible for Funding
No
No
N/A
To be eligible for funding, a PHA must submit a completed Appendix B in the notice to 2020COVIDHCV@hud.gov.
These funds may not be rolled into restricted net position (RNP) and must be tracked and accounted for separately through the period of availability.
Earlier today, HUD published PIH 2020-26, titled “Rental Assistance Demonstration (RAD) – Supplemental COVID-19 Guidance.” This notice does two things. First, in obligating operating funds for a RAD conversation in the first calendar year in which a housing assistance payment (HAP) contract is effective, this notice states that the project is eligible to receive up to the CARES Act operating fund grant amount provided (prorated by the number of ACC units converted and removed from PIC). Second it provides flexibilities for PHAs in conducting required resident meetings prior to conversion until Dec. 31 2020 due to the COVID-19 emergency.
Members of NAHRO will receive additional information on this notice.
In an email sent earlier today, HUD’s Office of Public and Indian Housing (PIH) announced that it will hold a call to discuss CARES Act reporting requirements and the Centers for Disease Control (CDC) eviction notice order. The call will occur at 2 pm ET on Sept. 15, 2020. Information on the call can be found below.
Step 1: Dial into the conference. Dial-in: 888-251-2949 or 215-861-0694 Access Code: 3278449## Need an international dial-in number? If the automated recording indicates the conference is full, please use overflow information: Dial in: 888-251-2949 or 215-861-0694 Access Code: 5358782#
Allows any PHA with a Housing Choice Voucher (HCV) program to apply for new Mainstream vouchers;
Provides Mainstream-voucher-specific waivers; and
Modifies the Housing Assistance Payment (HAP) renewal formula for Mainstream vouchers.
The deadline for applying for new voucher funding is Dec. 31, 2020. The additional flexibilities offered in this notice may be used until Dec. 31, 2020. Additional information on the new notice can be found below.