NAHRO Provides Recommendations to the HUD 2017 Transition Team

Today NAHRO provided members of President-elect Trump’s HUD transition team with the NAHRO Transition 2017 recommendations. All recommendations and positions in this document have been previously approved by our standing committees and the NAHRO Board of Governors. We also intend to make ourselves available to the new transition team and supply them with any and all information and assistance they may require from us to make the transition at HUD under the Trump Administration as smooth as possible.

The transition recommendations can be used as you reach out to your local HUD officials, your elected officials who will be seated in the new Congress, the media and your own state and local officials in a united effort to move a responsible and responsive housing agenda forward at HUD and on Capitol Hill. In addition to this document, the association will also be producing the NAHRO 2017 Regulatory and Legislative Agenda, which will be drafted over the coming weeks with input from NAHRO membership and leadership and will be available at the NAHRO 2017 Washington Conference.

NAHRO’s Transition 2017 recommendations for HUD may be viewed here.

HUD OIG Releases Report on Oversight of MTW Legal Costs

On September 29, HUD’s Office of Inspector General issued a report titled “HUD’s Oversight of Legal Costs at Moving to Work Housing Agencies.” The report found that HUD’s oversight was not adequate to ensure that legal costs spent by MTW agencies were reasonable and necessary.  OIG audited HUD on this topic due to congressional concerns, concerns from a previous external audit, and OIG’s initiative to focus HUD management’s attention on problem areas on which we and others have reported over the years.

According to the report, which audited 3 MTW agencies, payments for outside legal services paid for by the MTW agencies were not always in compliance with applicable requirements. The report claims that $9.2 million of the $16.5 million that the three agencies paid for outside legal services during the period October 2007 to September 2012 could be unsupported. The report notes that MTW agencies typically incur relatively higher costs for legal services than non MTW agencies.

OIG recommends HUD require MTW agencies to include a breakdown of their anticipated and actual costs for legal services in their annual plans and report.

NAHRO Attends Two-Day Research Advisory Committee Meeting on MTW Expansion

NAHRO attended the two day public meeting of the Moving To Work (MTW) Research  Advisory Committee held on September 1, 2016 and September 2, 2016. While a complete summary of the entire two-day meeting is outside the scope of this blog post, the Committee made some preliminary determinations of the policy interventions for the new MTW cohorts.

Each cohort will receive standard MTW flexibilities, except for where those flexibilities may conflict with a policy intervention being tested. The following policy interventions were the ones that the Committee determined HUD should further examine when moving forward with the expansion:

  1. General MTW Flexibilities – Cohort of 30 agencies (possibly two cohorts of 15 agencies each) which would be given all general MTW flexibilities. Would be restricted to only small agencies and would be compared to a control group of small agencies to test the effects of the “standard MTW package.”
  2. Rent Reform – This cohort would test the efficacy and tenant impact of stepped rent and possibly also flat rent and tiered rent.
  3. Project-Based Voucher Caps –  This cohort would test the effects of removing or increasing PBV caps.
  4. Sponsored-Based Housing – A cohort that would test the effect of sponsored-based housing. It is unclear what specific type of sponsor-based housing or the vulnerable population affected would be. The Committee was split on whether to recommend this.
  5. Landlord Incentives – This cohort would test a “satchel” of flexibilities (e.g., increased payment standards, cash to landlords, inspection flexibilities, etc.) to determine their combined effect. Agencies will be able to pick and choose which tools in the “satchel” they utilize.
  6. Place-Based Model – This cohort would try to measure the effects of place-based strategies towards housing. The was discussed very quickly at the end of the two-day long meeting.

These were the Committee’s recommendations to HUD about how it should move forward, but these policy interventions are not necessarily the ones with which HUD will choose to move forward. Everything is subject to change.

This was my recollection of the end of the two-day long meeting, but if you attended the meeting, either in-person or by phone, and want to add something, please feel free to leave a comment on this post.

Additional information will be posted on HUD’s MTW Expansion website located here.

NAHRO meets with HUD PIH Leadership

Georgi John HUD 16-8-9

NAHRO’s Acting CEO, John Bohm, and the NAHRO Policy Team members; Georgi Banna, Eric Oberdorfer and Tushar Gurjal; along with PHADA and CLPHA met with HUD’s Public and Indian Housing Principal Deputy Assistant Secretary (PDAS), Lourdes Castro-Ramierz, and many of the PIH department leadership.

Among the topics discussed were the priorities for implementing the Housing Opportunities Through Modernization Act (HOTMA/HR 3700); upcoming HUD rules such as Smoke-Free Housing, Small Area Fair Market Rents (SAFMRs), HCV Administrative Fee Formula; Moving to Work (MTW) Expansion; and Triennial Recertifications; and the current priorities of NAHRO, PHADA, CLPHA and HUD. NAHRO and CLPHA were also thanked for their current and continued work in affordable housing and education and the improvement of educational outcomes for the children our members serve.

NAHRO is committed to keeping open and productive lines of communication and will continue to share the thoughts and concerns of our members with HUD.

HUD Announces In-Person MTW Expansion Advisory Committee Meetings

HUD will host the MTW Expansion Research Advisory Committee for their 2 day, in-person meeting on Thursday and Friday, September 1 and 2. The in-person meeting will be held on Thursday, September 1, 2016 from 9:00 a.m. to 5:30 p.m. Eastern Daylight Time (EDT) and Friday, September 2, 2016 from 8:00 a.m. to 4:00 p.m. (EDT) at HUD Headquarters, 451 7th Street, SW, Washington, DC 20410. The meeting is open to the public and is accessible to individuals with disabilities.

The purpose of the meetings will be to discuss the framework and associated research methodologies for potential policies that HUD may require new MTW PHAs to test as a condition of admittance to the program. The Committee will discuss MTW Objective #1 (cost-effectiveness) and MTW Objective #2 (self-sufficiency)  on day 1, and will continue discussing MTW Objective #2 and Objective #3 (housing choice) on day 2. There will be time for public comment throughout the course of the meetings. NAHRO previously submitted comments to HUD on MTW policy proposals for the expansion and provided public comments during the Advisory Committee’s conference call last July (members only).

With advance registration, the public is invited to attend both days of the meeting in-person or by phone. Registration will be open from August 22 – August 26 here.

The agenda for the meetings can found here.

New Proposed Administrative Fee HUD FAQ posted

HUD has posted a new proposed administrative fee frequently asked questions (FAQ) document on its Housing Choice Voucher New Administrative Fee Formula Proposed Rule webpage. The new FAQ answers four questions:

  1. How is the benefit load calculated?
  2. How will the formula be applied to MTW sites?
  3. How are “per unit fees” and “total funding” calculated under the proposed rule formula and the existing formula?
  4. What does HUD mean by fee “received” under the current formula? How does proration fit in to the comparisons between the proposed formula and the existing formula?

Read the FAQ here.

For additional HUD analysis tools of the new proposed administrative fee formula, see our prior post.

HUD Holds MTW Expansion Teleconferences

HUD held its first two MTW Research Advisory Committee meetings on Tuesday, June 26 and Thursday, June 28. As stipulated by the FY 2016 Omnibus, the MTW Research Advisory Committee is tasked to advise HUD on how to move forward with the MTW expansion, especially with respect to specific policies to test in the expansion. The committee discussed potential policy proposals for each of the three statutory MTW objectives: cost effectiveness, self-sufficiency, and housing choice. On Tuesday, the committee discussed potential housing choice policies to implement through the expansion, and on Thursday, the committee discussed cost effectiveness and self-sufficiency. Thirty minutes per call were allotted to public comment. NAHRO staff commented on both calls, and transcripts of those comments can be found here and here (members only).

The committee will reconvene in person in Washington, DC sometime in mid-to-late August or early September. NAHRO staff plan to attend the in-person meeting.

Additional background information on the MTW Expansion can be found here (members only). NAHRO’s MTW policy proposals and research evaluation recommendations can be found here (members only).

NAHRO meets with HUD on Smoke-Free Rule and MTW Expansion; Briefing on SAFMRs

On June 29 and 30, NAHRO staff met with HUD staff to discuss the Moving to Work (MTW) Expansion that was included in the FY 2016 Omnibus and the upcoming smoke-free final rule. HUD also hosted a Small Area Fair Market Rent (SAFMR) proposed rule briefing.

Although HUD is still finalizing the MTW Expansion, they recently unveiled their MTW Expansion website, which contains information on the expansion process. HUD has also posted a MTW Expansion Frequently Asked Questions (FAQ) document.

According to HUD, a PIH notice should be published in the fall of 2016 soliciting applications for the initial cohort of new MTW PHAs. Additional cohorts of MTW PHAs will be added through separate notices through 2020 or until a total of 100 new MTW PHAs have been added. HUD has yet to determine the number of cohorts that will be included in the expansion nor specific policies to be tested through the expansion. The Secretary will weigh the advice of the MTW expansion advisory committee before determining both of these matters. For each cohort of new MTW PHAs, the specific policy proposals and methods of research and evaluation will be described in the PIH notice to be published in the fall of 2016. NAHRO’s policy proposals and recommended research evaluation methods for HUD regarding the MTW expansion can be found here (members only).

HUD plans to release the Instituting Smoke-Free Final Rule late summer or early fall. Although the rule is still undergoing the rule making process, NAHRO staff has learned HUD plans to submit the final rule to the Office of Management and Budget shortly. NAHRO was able to provide HUD staff with input on members concerns regarding the proposed rule. NAHRO’s comments on HUD’s proposed rule can be found here (members only).

HUD also hosted a briefing on the proposed SAFMR rule. The briefing went over the basics of the proposed rule and reviewed specific areas on which HUD was seeking comment. Comments and questions posed at the briefing from industry and advocacy groups included a question about the variability of all Fair Market Rents (FMRS) (to which HUD responded that they are working on a new methodology for FY 2017 FMRs); the current status of the SAFMR demonstration (it’s still going); and whether tenants who receive a subsidy cut in certain zip codes because of the SAFMR rule will be able to find housing in other zip codes because there are not enough available units or because landlords are not accepting vouchers (HUD does not know how to deal with this problem). Read our coverage of the proposed SAFMR rule here (members only).

 

HUD Publishes Names of Members of MTW Advisory Committee

On Wednesday, June 22, HUD published the names of the members of the MTW Advisory Committee. In its FY 2016 Appropriations bill, Congress directed HUD to expand MTW to include a hundred additional public housing agencies (PHAs) over the next seven years. Congress also called on HUD to establish a federal research advisory committee. The research advisory committee is responsible for advising HUD on specific policy proposals and methods of research and evaluation for MTW.

HUD has appointed the following people to the advisory committee:

  • Josh Meehan – Keene Housing;
  • Austin Simms – Lexington-Fayette Urban County Housing Authority;
  • Chris Lamberty – Lincoln Housing Authority;
  • Adrianne Todman – District of Columbia Housing Authority;
  • David Nisivoccia – San Antonio Housing Authority;
  • Janny Castillo – Former Resident of the Oakland Housing Authority;
  • Cindy Fernandez – Former Resident of the Housing Authority of Tulare County;
  • Asia Coney – Resident of the Philadelphia Housing Authority;
  • Larry Orr, Ph.D. –  Johns Hopkins University;
  • Heather Schwartz, Ph.D. – RAND Corporation;
  • Mark Joseph, Ph.D. – Case Western Reserve University;
  • Stefanie DeLuca, Ph.D. – Johns Hopkins University;
  • Jill Khadduri, Ph.D. – Abt Associates;
  • Marianne Nazzaro – HUD’s Office of Public and Indian Housing; and
  • Todd Richardson – HUD’s Office of Policy Development and Research.

HUD has also published an anticipated timeline for the expansion.

Early Summer 2016

Publish a summary of submitted comments on www.hud.gov/mtw.

Summer 2016

Begin the calls with the advisory committee, with an in-person meeting in Washington, DC in late-summer.

Fall 2016

Publish the notice to select the initial cohort of MTW agencies, with up to four months to submit applications.

Spring/Summer 2017

Select initial cohort of new MTW public housing authorities.

 Additional Resources:

Read the full HUD Press Release here.

Read NAHRO’s coverage of the FY 2016 appropriations bill and the included MTW expansion here.