As previously mentioned on this blog, IMS-PIC will be down starting tomorrow (Friday, 3/13/2020) until the Monday after next (Monday, 3/23/2020). During this period, housing agencies are asked not to use the system so that a security-related patch may be applied. The Department is encouraging PHAs with programs with fiscal years that end prior to Dec. 31 to complete submission of their SEMAP certification prior to the system entering the shutdown phase. When the system resumes operation, the Department will publish step-by-step instructions for PHAs and Field Offices to address potential problems.
A recording of HUD’s webinar on Infectious Disease Preparedness for Homeless Assistance Providers and Their Partners has been posted. It can be found below.
The HUD Exchange sent an email of links to new material from the Centers for Disease Control and Prevention (CDC) for Homeless Assistance Providers. The new materials include the following:
Tomorrow, HUD will publish a notice in the Federal Register announcing the creation of a HUD guidance portal. In the process of complying with a presidential executive order, the Department conducted a review of all of its guidance and ensured that those documents that remain in effect were linked to a single website that could be searched. The single searchable database containing all of HUD’s guidance can be found at:http://www.hud.gov/guidance.
The National Association of Housing and Redevelopment Officials applauds HUD for creating this searchable index and looks forward to further refinements.
The pre-publication copy of the notice announcing this portal can be found here.
The Department has released a new Infectious Disease Toolkit for Continuums of Care (CoCs). The toolkits provide “structure and specific examples for planning and responding to influenza, coronavirus, and other infectious diseases.” The toolkit is composed of three documents for CoC leadership, homeless service providers, and other partners to use in responding to infectious diseases. The documents include the following:
Additionally, one of our members wanted to share these coronavirus anti-stigma resources. They mostly apply to the local King County / Seattle area, but others may also find them useful.
Last week, HUD published a notice in the Federal Register titled “Administrative Guidelines: Subsidy Layering Review for Project-Based Vouchers.” Subsidy layering reviews (SLRs) ensure that excessive public assistance is not used when combining Housing Assistance Payments (HAP) from project-based vouchers with other forms of public assistance from federal, state, or local agencies including through tax assistance or credits. Subsidy layering reviews are not required when a project is already subject to a project-based voucher (PBV) contract (even if it is recapitalized with outside funding) or when PBVs are the only assistance provided to a development. Subsidy layering requirements are required when a PBV project includes other governmental assistance. The Department and, in certain cases, the local Housing Credit Agency are the entities that conduct the review. This notice provides information about subsidy layering reviews with appendices on PHA submissions required, a sample notice of intent to participate in subsidy layering reviews by housing credit agencies, and a sample housing credit agency certification.
Tomorrow HUD will publish in the Federal Register “Economic Growth, Regulatory Relief, and Consumer Protection Act: Initial Guidance on Property Inspections and Environmental Reviews.” The act referred to in the notice is commonly call by its Senate bill number, S. 2155 and S. 2155 will be used in this post to refer to the act. NAHRO worked very closely with Congress to ensure S. 2155 provided statutory and regulatory relief to small PHAs across the country. Additionally, NAHRO also submitted comments to help guide HUD in the implementation of the provisions, many of which HUD incorporated into this notice. NAHRO is thrilled to see the critical provisions of S. 2155 being implemented!
The notice also resolves a key sticking point in the implementation of S. 2155 – what is a small rural PHA? HUD defines “small rural PHA” as a PHA that operates 550 or fewer combined Public Housing and Housing Choice Voucher units and predominantly operates in a rural area. The notice takes NAHRO’s suggestions to exclude Project-Based Rental Assistance (PBRA) units in determining unit count. The notice also draws heavily on NAHRO’s comments on how to define “predominantly operates,” taking two out of three of NAHRO’s suggestions on the definition. “Predominantly operates in a rural area” is defined as having a primary administrative building with a physical address in a rural area OR more than 50 percent of its combined Public Housing units and voucher units under Section 8(o) are in a rural area. Rural area is defined by a Consumer Financial Protection Bureau regulation. Currently there are 1,519 PHAs that qualify as a “small rural PHA” under this definitions and HUD has published a list of small rural PHAs (scroll to bottom on HUD link page).
Map of Small Rural PHAs
The notice also implements potions of the property inspection and environmental review provisions of S. 2155.
Small rural PHAs that operate the Housing Choice Voucher programs can now inspect their tenant-based and project-based vouchers units every three (3) years. This new inspection schedule will begin for the small rural PHA after its next currently schedule inspection. Small rural PHAs must continue to conduct any lead safety inspection that are required under the Lead-Based Paint Poisoning Prevention Act.
Small rural PHAs will now be exempt from Environmental Reviews with respect to development or modernization projects that cost no more than $100,000. This exemption applies to any section 9(d) Capital Fund, section 9(e) Operating Fund, or section 8(o)(13) Project Based Voucher (PBV) eligible work activity by a small rural PHA at a project site with a project cost of $100,000 or less. For project with a cost of more the $100,000, the small rural PHA must complete the appropriate Environmental Review but HUD will use the rulemaking process to proposed streamlined Environmental Reviews.
NAHRO will continue to work with HUD to ensure full implementation of S. 2155, Economic Growth, Regulatory Relief, and Consumer Protection Act.
As previously mentioned on this blog, the Vera Institute of Justice (Vera) is seeking applications for technical assistance from PHAs that would like to plan and implement reentry programs or change their policies toward people with conviction histories. Applications are due in one week on Friday, February 28, 2020.
The goals of the initiative include the following: increase housing for people with conviction histories while increasing public safety; improve the safety of public housing through the use of reentry strategies; and promote collaboration between PHAs, law enforcement, and other criminal justice stakeholders.
Housing authorities of all sizes (including those with housing choice vouchers) are encouraged to apply. Applicants must submit a letter of intent, an application narrative, and letters of support. Award announcements will be made in April.
Earlier today, HUD announced that it published a Housing Choice Voucher Dashboard. The dashboard provides information about vouchers at both the state and national levels. It includes budget and leasing utilization information, reserve balance information (it highlights PHAs that have high reserves as a percentage of their budget authority and in absolute terms), attrition, per unit cost trends, and leasing potential. There is also utilization data on special purpose vouchers (HUD-VASH, FUP, Mainstream, etc.). The data is mostly taken from the voucher management system.
The NAHRO Blog: Legislative & Policy Updates from Washington, DC 