HUD Issues Letter Confirming New Micro- and Simplified Acquisition Thresholds

Last week, HUD sent a letter to Executive Directors confirming that the micro-purchase threshold and the simplified acquisition threshold have been increased. The new thresholds are as follows:

  • the micro-purchase threshold is now $10,000 (previously, it was $3,500); and
  • the simplified acquisition threshold is now $250,000 (previously, it was $100,000).

There was initially uncertainty about the use of these thresholds since the summer of 2018, when the Office of Management and Budget (OMB) published a notice implementing increases to the thresholds for all grant recipients. This letter clarifies that the increased thresholds apply to PHAs.

OMB’s original notice can be found here.

HUD’s letter confirming the new thresholds can be found here.

HUD Publishes Guidance on (S. 2155) Economic Growth, Regulatory Relief, and Consumer Protection Act

(2/14/19 Update – the copy below is a pre-publication copy of the notice. The final copy published in the Federal Register today can be found here. Comments are due by April 15, 2019.)

Earlier today, HUD published in the Federal Register a notice titled “Section 209 of the Economic Growth, Regulatory Relief, and consumer Protection Act: Initial Guidance.” The act added section 38 to the United States Housing Act of 1937 which require amendments to regulations that govern small public housing agencies (PHAs) that administer 550 or fewer combined public housing units and vouchers that predominately operate in a rural area and certain other regulations.

While certain statutory provisions under the notice become active after 60 days after the act passes, these provisions require rulemaking or guidance for implementation. Through this guidance, HUD also seeks comment on the appropriate implementation of these provisions. Comments are due 60 days from today. Guidance and requests for comment are on the following:

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Public Housing Operating Fund Payments for March, April, and May Prorated at 88.7%

Earlier today, HUD sent an email to PHA Executive Directors informing them that HUD will make subsidy obligations available in the Line of Credit Control System (LOCCS) for the Public Housing Operating Fund within the next six business days. The payments for the months of March, April, and May will be obligated at a 88.7 percent proration. Although PHAs are being funded for three months, they are required to only draw down funds one month at a time, unless a multiple month withdrawal is approved by a HUD field office.

The funds being obligated are based on an estimate of PHA eligibility. The department believes that it should know actual eligibility, based on PHA submissions, by June at the earliest. As certain developments may be under- or over-funded based on current estimates, in instances where the estimated funding varies from the actual eligibility, the PHA should contact its field office representative. The PHA should also refrain from drawing down overfunded amounts and–if underfunded–should utilize its reserves until it receives its actual eligible funding.

If a development has been fully converted to RAD in 2018, but has still been awarded 2019 Operating Funds, the PHA should advise its field office immediately and not draw down 2019 funds.

The full notice can be found here.

HUD Sends Additional Information About PH and HCV Payments

Earlier today, HUD sent an email to Executive Directors with additional information about future payments for the Housing Choice Voucher (HCV) program and the Public Housing (PH) program. The email noted that the federal government was operating under a continuing resolution (CR) until Feb. 15, and provided information for potential future payments, if additional money is not allocated by Congress (either by extending the CR or passing a full budget).

2019 PH and HCV Funding

 

March

April

May

HCV HAP

On time; 99% proration

On time; 99% proration

Awaiting information from HUD

HCV Admin. Fee

On time

On time

Awaiting information from HUD

PH Operating Fund

On time; 88% proration

On time; 88% proration

On time; 88% proration

HCV Funding – The HAP prorations are calculated without applying Renewal Funding Inflation Factors (RFIFs). In some places, the actual HAP required may be greater than the amount disbursed as the HAP calculation is not factoring in rising rental prices. Those PHAs with HUD-held reserves (HHR) will still be able to request additional funding from their reserves, if the HUD amount is not enough to cover the PHA’s HAP needs through April. Additionally, some March and April disbursements may automatically include funding from the PHA’s available HHR, if required to meet the PHA’s HAP requirements. The Department has enough funding for March and April administrative fee payments and will also make HAP and administrative fee disbursements for mainstream vouchers for March and April. Finally, in situations where the availability of HCV or mainstream vouchers is in risk, HUD is planning to provide additional guidance on the use of outside funds for HAP and administrative fees–including modifications to the approval process (note: NAHRO asked HUD for this guidance and to modify the approval process). Questions may be directed to PIH.Financial.Management.Division@hud.gov.

PH Funding – The Department will provide funding based on a conservative estimate of need. As HUD receives data on need, it will update funding eligibility.

The full email can be found here.

HUD Updates Shutdown Reserve Guidance for MTW Agencies

Earlier today, a HUD official sent an email to Executive Directors at MTW agencies providing additional guidance on when it is appropriate for MTW agencies to access HUD-held reserves. The guidance is reproduced below.

Dear Executive Director,

The letter sent to your PHA dated January 15th regarding access to the HHR and setting out criteria for requesting HHR applies to MTW and non-MTW PHAs.  During a lapse in appropriations, HUD staff is only permitted to work on certain activities, including activities that address threats to human lives and properties.  As an MTW PHA, if you believe you need access to the HHR to address immediate threats to the health and safety of tenants or the preservation of property beyond those in the January 15th letter, please submit the amount, a justification for the amount, the intended programmatic use (e.g., public housing, low-income housing), and the timing of expenditure to Robert Boepple at robert.h.boepple@hud.gov.

One More Week!! – MTW Expansion Letters of Interest Due Jan. 11

PHAs interested in applying to the first cohort of the Moving to Work (MTW) Expansion must submit their letter of interest to HUD by January 11. Due to the current government shutdown, HUD will not respond to your submitted letter of interest until the government reopens. Regardless, NAHRO recommends that all PHAs interested in applying to the first cohort submit their letters to HUD on or before the January 11 deadline. The HUD notice describing the requirements for letters of interest is here, and letters of interest should be sent to mtw-info@hud.gov. In October 2018, HUD released a notice describing the requirements needed for letters of interest.

PHAs with 1,000 or fewer aggregate units (including special purpose vouchers) are eligible to apply to the first cohort of the MTW Expansion, which will examine the overall impact of MTW flexibility. Before applying, PHAs must complete a baseline research survey that identifies the characteristics of all applicants. After submitting the baseline research survey, PHAs must complete a letter of interest stating a desire to obtain MTW designation, which cannot be longer than two pages and must be signed by the Executive Director. The PHA’s Board of Commissioners must also pass a resolution stating a desire to obtain MTW designation under the first cohort. Lastly, the PHA must also complete a certification of commitment (Attachment I – last few pages).

After the application deadline passes, HUD will divide eligible applicant PHAs into groups based on their geography and then randomly assign each PHA within a geographic area to one of three groups: a treatment group (which will be invited to continue to step 2 to apply); a waitlist group (which may be invited to apply, if a treatment group PHA withdraws); or a control group (which will not receive MTW status, but is expected to participate in the first cohort evaluation). PHAs in the waitlist group will be moved to the control group once the treatment group has 30 PHAs which successfully apply.

NAHRO will continue to monitor the MTW application process and any effects of the government shutdown. We will provide updates as we learn them.

The MTW Operations Notice can be found here.

The first cohort application notice can be found here.

Complimentary Smoke-Free Webinars in 2019

Join Clean Air For All, a joint effort between NAR-SAAH, NAHRO, and Live Smoke Free on third Thursday of the month, for a live discussion and Q&A on the “Instituting Smoke-Free Public Housing” final HUD rule. Participants will hear a brief update on the rule and will be able to submit questions to NAR-SAAH, NAHRO, and Live Smoke Free staff. Have your questions about the rule, cessation resources, and enforcement answered.

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These calls are intended for those working and living in affordable housing. The January, March, May, July, September, and November calls will have a housing authority staff focus while the April, June, August, October and December calls will have a resident service provider, resident leader, and resident focus. Everyone is welcome to attend all of the calls and hear the various perspectives.

The January Connect Call will have a guest speaker from Leading Age, the trusted voice for aging in America, will join us to provide tips and strategies for working toward compliance with aging residents in smoke-free public housing.

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HUD Announces Action Plan to Reduce Childhood Lead Exposure

Yesterday, in a press release, the administration announced a join action plan by the Department of Housing and Urban Development (HUD), the Environmental Protection Agency (EPA), and the Department of Health and Human Services (HHS) to reduce childhood lead exposure and associated health impacts. Secretary Carson has stated that “[i]mplementing this plan will help federal agencies, along with our state and local partners, advance efforts to remediate home health hazards and keep children safe from lead poisoning.”

The plan has four goals:

  1. Reduce children’s exposure to lead sources;
  2. Identify lead-exposed children and improve their health outcomes;
  3. Communicate more effectively with stakeholders; and
  4. Support and conduct critical research to inform efforts to reduce lead exposure and related health risks.

The plan notes that while it “is not a budget document and does not imply approval for any specific action . . . [i]t will inform future federal budget and regulatory development processes within the context of the goals articulated in the President’s Budget.”

The full press release can be found here.

The action plan can be found here.

HUD Broadcasts Webinar on MTW Cohort #1

Earlier today, HUD broadcast a webinar on the Moving to Work (MTW) Expansion Cohort #1. The webinar explained what MTW was, explained the benefits of an MTW designation, provided presentations from current MTW agencies, and discussed the process by which agencies could apply for Cohort #1. Additionally, questions from webinar participants were answered.

The webinar also gave the following timeline for MTW Expansion activities:

  • Spring 2019 – Revise MTW Operations Notice based on public comment and publish final MTW Operations Notice;
  • Summer / Fall 2019 – Designate the initial cohort of MTW agencies; invite the second cohort of agencies to apply;
  • Winter 2020 – Designate the second cohort of MTW agencies.

The full webinar with audio and the slide presentation will eventually be posted on HUD’s MTW Expansion site, but an unofficial copy of the slides from the webinar can immediately be found here.

HUD Posts RAD Rent Levels for 2019 (Based on 2018 Public Housing Funding Levels)

Earlier today, the Department of Housing and Urban Development sent an email through its RADBlast! email list announcing RAD rents levels for 2019 (based on 2018 Public Housing Funding Levels). These rents will be used for new awards used in 2019. They may also be used for current awardees to update rents in existing Commitments to enter into Housing Assistance Payment contracts (CHAPs). Closed transactions are ineligible to receive these new rents. Remember, these new rents–after being updated with 2019 Operating Cost Adjustment Factors (OCAFs)–may not necessarily be higher than your current CHAP rents depending on how the transaction is structured. NAHRO strongly recommends carefully reading HUD’s Frequently-Asked-Questions (FAQ) document on updating RAD rents before requesting updated rents.

Additionally, HUD has created a streamlined, online RAD application for public housing conversions that can be accessed here.

The 2019 RAD Rents can be accessed here.

The FAQ can be found here.