HUD Awards Public Housing Capital Funds

Today HUD awarded the FY 2018 Public Housing Capital Fund grants to housing authorities in all 50 states, as well as the District of Columbia, Guam, Puerto Rico and the U.S. Virgin Islands. The grants total more than $2.6 billion.

A list of the individual housing authority grants is available here.

An excerpt from the HUD press release states, “The grants announced today are provided through HUD’s Capital Fund Program, which offers annual funding to approximately 3,100 public housing authorities to build, repair, renovate and/or modernize the public housing in their communities. These housing authorities use the funding to complete large-scale improvements such as replacing roofs or making energy-efficient upgrades to replace old plumbing and electrical systems.”

HUD Sends FSS Program Coordinator Funding Letter

Earlier today, HUD sent a Fiscal Year 2018 Family Self-Sufficiency Program Coordinator Funding Letter to PHA Executive Directors. The letter is meant to help “prepare for the upcoming Fiscal Year (FY) 2018 Family Self Sufficiency Notice of Funding Availability (NOFA) competition.” The letter discusses Public and Indian Housing Information Center (PIC) data; the possible use of composite scores in funding determinations; and checking the System for Award Management (SAM) and DUNS status.

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How Will MTW “Accommodate Regionalization”?

On the Brookings website, there’s a joint post by Greg Russ, the Executive Director and CEO of the Minneapolis Public Housing Authority, and Robin Snyderman, a Nonresident Senior Fellow of Brookings’s Metropolitan Policy Program, which discusses the new Moving To Work (MTW) Expansion. The post focuses on the MTW expansion enabling legislation which allows HUD to “accommodate regionalization” in its MTW expansion plans.

What this legislative language specifically means is unclear, but the opportunity exists to use the MTW Expansion and its single-fund flexibilities to create a “a variety of public housing initiatives to operate in a regional market across agency boundaries.” Regional MTW approaches may be particularly relevant in Baltimore, Chicago, and the Twin Cities, where MTW agencies are located in high-poverty areas surrounded by other PHAs in lower-poverty jurisdictions.

In fostering a regional MTW approach, agencies will still need to properly balance the greater cost of mobility initiatives with the tradeoff of potentially serving fewer families. The post notes that one of the benefits of a regional MTW approach may be “the cost-savings associated with reduced administrative burdens of cross-jurisdictional activity.”

The post explores other concepts of what MTW regionalization may look like.

The entire post can be read here.

Past Due Section 3 Reports Due July 31, 2017

On July 7, 2017, HUD’s Economic Opportunity Division of the Office of Fair Housing and Equal Opportunity issued a notice regarding Section 3 reporting due dates for PHAs. Reporting due dates for PHAs are now based on the PHA fiscal year end (FYE), and generally are due 60 days after the PHA FYE. Non-PHAs that are recipients of Section 3 funding will continue to submit annual reports as they have done so in the past.

However the notice did provide specific dues dates for past due reports. Past due Section 3 reports for 2013, 2014, and 2015 must be submitted by July 31, 2017. Also Section 3 reports for 2016 are due 60 days after the PHA FYE, if not already submitted. For 2017 and beyond, Section 3 reports are due 60 days after PHA FYE.

The process of for electronically submitting your Section 3 reports can be found on the HUD website.

MTW Operations Notice Comment Period Reopens

In today’s Federal Register Public Inspection Documents, HUD included, “Operations Notice for the Expansion of the Moving to Work Demonstration Program Solicitation of Comment; Waiver Revision and Reopening of Comment Period.” It is anticipated that this notice will be published in the Federal Register tomorrow, May 4, 2017.

This notice reopens, for 30 days from its publication in the Federal Register, the comment period of the January 23, 2017 Moving to Work (MTW) Operations Notice. This notice also makes revisions to one General Waiver in Appendix 1 and two Conditional Waivers in Appendix 2.

The General Waiver that is revised focuses on the Family Self-Sufficiency (FSS) program and the updated waiver allows housing agencies to require participation in an FSS program. If an agency makes FSS participation mandatory, the agency must also have and apply exceptions and hardship provisions.

The two Conditional Waivers that are revised focus on Work Requirements for Public Housing (PH), and Housing Choice Voucher (HCV) and Project-Based Voucher (PBV) residents. The first waiver is for “PH — Work Requirements” and the second is for “HCV & PBV — Work Requirements” but the revision is the same – the housing agency may implement work requirements for PH, HCV, and PBV residents between the ages of 18 and 61. The previous versions of these waiver listed 54 as the maximum age.

NAHRO will continue to engage with HUD and housing agencies to maximize the regulatory relief and flexibility essential to the MTW program and the MTW expansion.

HUD to Host MTW Listening Sessions

Earlier today, a NAHRO member forwarded an email sent by General Deputy Assistant Secretary Bryon of HUD’s Office of Public and Indian Housing announcing four listening sessions “for PHAs that are interested in applying to MTW and other industry partners.” Through the listening sessions, HUD hopes to hear feedback on its MTW Operations Notice. The MTW Operations Notice will govern the operation of PHAs that are selected to participate in the 100 PHA Expansion of the MTW Demonstration Program.

HUD is particularly interested in feedback on the following topics:

  • Evaluation and performance assessment;
  • Calculation of funding;
  • Statutory and regulatory waivers; and
  • Regionalization.

The listening sessions will be held in the following cities on the dates listed next to location (click on the location to register):

NAHRO’s comments on the MTW Operations Notice can be found here.

NAHRO Releases Preliminary Joint FY 2018 Budget Recommendations with PHADA and CLPHA

Yesterday, April 6, NAHRO released joint budget recommendations with industry groups CLPHA and PHADA. The document containing the recommendations states that the recommendations “are based on the best information available at this time. [The three groups] will submit revised funding recommendations to Congress when more detailed and timely information, such as the President’s FY 2018 budget request and Congressional Justifications, becomes available in May.”

These recommendations would fully fund the Operating Fund and provide enough funding for the Capital Fund for PHAs to begin addressing their capital needs backlog. Additionally, these recommendations would fully fund voucher renewals, fully fund the administrative fee formula, and fully fund project-based rental assistance contracts. The recommendations also provide sustainable funding for other important programs.

NAHRO / PHADA / CLPHA FY 2018 Funding Recommendations (in millions)
Public Housing Operating Fund $5,349
Public Housing Capital Fund $5,000
Emergency Capital Needs $21.5
Resident Opportunities and Supportive Services (ROSS) $35
Jobs Plus $15
Public Housing Financial and Physical Assessment Activities $10
Section 8 Tenant-Based Housing Choice Voucher HAP Renewal $19,390
Section 8 Ongoing Administrative Fees $2,284
Section 8 Project-Based Rental Assistance $11,400
Consolidated Family Self-Sufficiency (FSS) Program $95
Choice Neighborhoods Initiative $200

The “Emergency Capital Needs,” “Resident Opportunities and Supportive Services (ROSS),” “Jobs Plus,” and “Public Housing Financial and Physical Assessment Activities” accounts are in addition to the amount requested for the Capital Fund and are not sub-accounts.

The entire document with the FY 2018 budget recommendations–which contains additional information about each of the accounts–can be found here.

HUD Publishes Cash Management Notice for HCV Program

Yesterday, March 23, HUD published PIH-2017-06, a notice titled “Cash Management Requirements for the Housing Choice Voucher Program.” This notice replaces the previous cash management notice (PIH 2011-67) and “revises the cash reconciliation timeframes and provides additional guidance to MTW PHAs.”

While NAHRO will provide additional coverage of the notice in its the next issue of its newsletter, the Monitor, here are few points from the notice.

  • Monthly disbursements are based on the most recent validated Voucher Management System (VMS) Housing Assistance Payment (HAP) costs. Disbursements may be scheduled for one or multiple months at a time. Disbursements will be made on the first business day of the month. The notice provides an example document showing how PHAs will be notified of disbursements.
  • HUD assesses national program cost trends and may include small increases or decreases to disbursement amounts to account for increases or decreases in national leasing or other costs.
  • PHAs whose monthly costs exceed the scheduled disbursements may submit a request for additional advance to their Financial Analyst at the Financial Management Center (FMC).
  • Disbursements will be scheduled for deposit in a PHA’s bank on the first business day of the month.
  • At least twice a year HUD will compare a PHA’s actual costs to funds disbursed plus other program revenues (e.g., fraud recoveries). Future disbursements will be adjusted accordingly. HUD will address disbursement shortfalls at a reconciliation at the end of the calendar year. In the end-of-the-year reconciliation, if HAP expenses were less than total HAP disbursement combined with other program revenue and Restricted Net Position (RNP), there will be an offset.
  • HUD will process prior period adjustments once in the next year.
  • The notice provides a sample document HUD will use following each interim and year-end cash reconciliation.
  • Incremental vouchers (i.e., first time vouchers) such as HUD-VASH or tenant protection vouchers will have their funding disbursed in equal monthly amounts according to the effective date and expiration dates of their contracts.
  • Excess HAP and RNP are to be deposited in an interest-bearing account and at least once a year, PHAs are required to remit that interest to the Treasury.
  • PHAs are still able to access their program reserves for eligible HAP needs whenever necessary by contacting their Financial Analyst at FMC.

MTW Agencies

MTW agencies are subject to cash management requirements. Non-HAP expenses funded from HAP are not considered for the monthly HAP disbursement calculations. Any MTW PHA that needs more than the calculated amount should contact their Financial Analyst at the FMC for additional disbursement, which may include eligible MTW non-HAP expenses.

Additional coverage on the notice will be forthcoming for members. The notice can be read here.

 

HUD Sends 2017 HCV Program Renewal Funding Letter

Today, March 15, HUD sent a letter to Executive Directors about 2017 Housing Choice Voucher (HCV) renewal funding. The letter purports to provide guidance in HCV Program planning.

The letter notes that the Department would normally have 60 days to calculate a PHA’s funding level after a full-year budget or a full-year Continuing Resolution (CR), but currently the Department has neither a full-year budget nor a full-year CR and is operating under a CR that is a few months long. It is operating under a CR that lasts until April 28, 2017.  This partial-year CR makes planning difficult. HUD believes that they will only have definitive budgetary information for FY 2017 in June 2017.

Despite this, HUD has evaluated several situations to provide PHAs with potential guidance in HCV Program planning. The letter notes that in calculating national voucher costs a significant inflation factor was applied. There was at least a 2.58% inflation factor applied to all PHAs. Forty percent of PHAs received a higher inflation factor.

  • Scenario 1 – Full Year CR (FY 2016 Appropriation Levels):
    • HAP proration – 94% and
    • Administrative Fee proration – 77%.
  • Scenario 2- Full Year budget passed:
    • Using Senate Appropriations bill numbers:
      • HAP proration – 97.5% and
      • Administrative Fee proration – 80%.
    • Using House Appropriations bill numbers:
      • HAP proration – 97.5% and
      • Administrative Fee proration – 75%. [4:03 pm edit – number corrected.]

The letter states that “a full year CR seems to be the responsible starting point for program operations . . . [and] PHAs should assess their projected leasing and spending starting with the 94% proration . . . [and] model alternative scenarios.” HUD also recommends using the HCV Forecasting Tool and modeling different proration scenarios (the forecast tool defaults to 94% currently).

NAHRO agrees that it is safe assumption to assume a full year CR for FY 2017 in program planning.

The full letter can be read here.

HUD Issues Notice on Temporary Census Income

On March 7, HUD issued a Notice PIH 2017-5, “Income exclusion under temporary Census employment and Census access.” The notice emphasizes the importance of accurate census data to the HUD programs and discusses how PHAs and other certain HUD grantees must handle a family’s temporary census income along with providing census workers access to buildings.

HUD regulations require temporary, sporadic, nonrecurring income not to be included in the family income calculation. The notice states, “Under this exclusion, PHAs exclude temporary income payments from the U.S. Census Bureau, defined as employment lasting no longer than 180 days per year and not culminating in permanent employment.” This provision applies to all PHAs and HUD grantees that calculate family income under 24 CFR 5.609.

This notice also reminds building managers to provide census workers access to properties. Specific mention of providing census workers access to properties with federally assisted tenants is also made in the notice.