HUD Sends Letter to PHAs in Declared Disaster Counties on Hurricanes Harvey, Irma, and Maria

On Tuesday, September 26, HUD sent an email to PHA Executive Directors in Declared Disaster Counties. The email provides information that may be useful for PHAs in those areas.

Federal Emergency Management Agency (FEMA) Public Assistance Program – PHAs in declared disaster areas may be eligible to apply for Stafford Act Section 403 and Section 406 funds through FEMA’s Public Assistance Programs program. The Public Assistance grant program covers emergency work (covered by Section 403; e.g., debris removal, demolition of unsafe structures; or boarding of windows) and permanent work (Section 406), unless Congress appropriates funds to HUD for these purposes. Additional information on this FEMA program can be found here.

FEMA and HUD Data Sharing – Starting the week of September 18, HUD’s Office of Public and Indian Housing (PIH) began sending reports to PHAs about program participants who have registered for FEMA assistance. HUD anticipates continuing to send these reports on a weekly basis or as new information is available. Please use discretion handling the workbooks and data.

Fraud – If PHAs have concerns about fraud, the email lists methods to contact the federal government.

FEMA’s Fraud Hotline – (866) 720-5721 and

HUD OIG’s Fraud page – (800) 347-3753.

Expedited Waiver Process – As mentioned in NAHRO’s previous blog post, HUD is in the process of creating a expedited waiver process for those PHAs in disaster areas. The process will be articulated in an upcoming Federal Register notice. This notice will be modeled on previous expedited waiver process notices.

Additional information on the Hurricanes and HUD’s response can be found at the following links:

HUD OIG Publishes Semiannual Report to Congress

HUD’s Office of Inspector General (OIG) has published it’s Semiannual Report to Congress for the second half of fiscal year 2016. These reports are “intended to keep the Secretary and the Congress fully informed of significant findings, progress the Agency has made and recommendations for improvement.”

The report can be found here.

HUD to Hold COCC Listening Session in Los Angeles

NAHRO encourages all PHAs, especially those on the West Coast, to attend the HUD COCC (Central Office Cost Center) listening session on December 7, 2016 in Los Angeles, CA. Previous COCC listening sessions have been held in Alabama, Michigan and the District of Columbia. NAHRO has participated in a HUD COCC listening session and HUD shared substantive information in addition to listening to the concerns and questions of PHAs. These listening session are not part of the formal rulemaking process and is an opportunity to have a discussion with HUD on the COCC and the fee system.

PHAs interested in attending the COCC listening session in Los Angeles on December 7, 2016 will need to register at the following website: http://www.hud.gov/emarc/index.cfm?fuseaction=emar.registerEvent&eventId=2944&update=N.

Below is the Los Angeles COCC Listening Session information and agenda that was received from HUD.


In consideration of those PHAs that are located on or closer to the West Coast, HUD has decided to offer an additional COCC Listening Session in Los Angeles, CA on Wednesday, December 7, 2016.  Registration information for the Los Angeles, CA session is provided below.   

Background: In response to an OIG audit report, HUD is considering changes to the amount and types of fees a PHA’s Central Office Cost Center (COCC) can charge and the eligible uses of these funds by the COCC.  These changes could significantly impact the more than 600 PHAs that operate under asset management using the COCC model.  To more fully understand the impact of such changes when developing possible new rules, procedures, and guidance on the COCC, HUD has chosen to hold listening sessions in several cities, including Los Angeles, CA.

We welcome your PHA’s participation.

Detailed information on the COCC listening session and registration information is provided below.  Note: The listening session is in person only; there is no audio or video broadcasting of the sessions.

D.J. Lavoy,

Deputy Assistant Secretary

PIH-Real Estate Assessment Center


Who Should Attend? The target audience for this listening session is Executive Directors, Chief Financial Officers, and Public Housing Directors of PHAs that operate under asset management using a COCC.  PHAs also are encouraged to share this information with their fee accountants and auditors.  HUD will be sending a separate email to invite fee accountants, auditors, and financial consultants to the listening session.

Listening Session Registration. Registration is limited to no more than two (2) participants from the same PHA or organization.  To register for the Los Angeles session, please click on the link below.

http://www.hud.gov/emarc/index.cfm?fuseaction=emar.registerEvent&eventId=2944&update=N

The event will be held at HUD’s Los Angeles, CA Field Office.  Take the elevator directly to the 4th floor to Room 4054.

Los Angeles Federal Building

300 North Los Angeles Street, Suite 4054

Los Angeles, CA 90012

Note: Attendees will be asked to go through a metal detector and place their personal items through an x-ray machine.  With this in mind, please give yourself an extra 15 to 20 minutes to go through security and consider what you bring with you.

COCC Listening Session Agenda. A draft agenda for the COCC listening session is provided below.

COCC Listening Session – Draft Agenda
# Topic Time
1 Onsite Registration 8:30 – 9:00
2 Welcome and Background 9:00 – 9:30
3 Reasonableness of Fees and Fee Type 9:30 – 10:15
4 Re-federalization of Fees 10:15 – 10:45
5 Break 10:45 – 11:00
6 Eligible Uses of Fee Income 11:00 – 12:00
7 Lunch 12:00 – 1:00
8 Accounting and Reporting 1:00 – 2:15
9 Break 2:15 – 2:30
10 Transition Items 2:30 – 3:30
11 Next Steps / Closing 3:45 – 4:00

Lodging/Parking Information. For attendees who may need overnight accommodations or parking, this information is provided at the link below.  This hotel list is provided for your convenience.  HUD does not endorse or recommend any hotel.

https://drive.google.com/file/d/0B1BC9D4S6JWMcmEwYWhOYjd6eGM/view?usp=sharing

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.

Handling Conflicts of Interest

On September 6, HUD’s Office of Inspector General (OIG) published a bulletin titled “7 Keys to Handling Conflicts of Interest.” Conflicts occur when “officials or staff stand to benefit–either directly themselves or indirectly through business partners or relatives–from the awarding or contracting of grant funds.” The bulletin lists points to remember when handling conflicts of interest:

  1. Know the Requirements;
  2. Train Employees;
  3. Create Procedures to Document Compliance;
  4. Implement the Regulations;
  5. Know the Consequences;
  6. Request an Exception; and
  7. Get Help.

The full bulletin, with examples, can be found here.