NAHRO’s New Housing Proposals Focus on the Future

The nation’s public housing agencies and community development agencies have been housing our nation’s families and creating vibrant, stable communities for decades. And they’re continuing to do this vital work of providing shelter, creating opportunity, and addressing inequities during a pandemic that’s straining both local and national resources.

But even as we continue to cope with the fallout of COVID-19, we must also work on solutions for both current and future housing needs. We need new housing construction, more resources for existing housing programs, and flexibilities that prioritize progress over paperwork. NAHRO’s What Happens Next: Housing Beyond the Pandemic provides funding and policy proposals that will:

  • Increase housing supply and improve affordability
  • Preserve existing affordable housing
  • Stabilize families, and
  • Prioritize progress over paperwork.

The paper is available here.

HUD Extends Section 3 Reporting Deadline until July 31, 2020

Earlier today, HUD’s Office of Fair Housing and Equal Opportunity sent an email to PHAs extending the deadline for submission of all Section 3 annual reports until July 31, 2020 because of the COVID-19 event. This does not impact reporting for agencies with deadlines due after the extension date. In the email, the Department also reminds PHAs that the SPEARS system transmits emails to agencies with reports due or overdue, and these emails should be ignored for those PHAs complying with this extension.

[6/10/2020 edit – typographical correction.]

HUD’s Section 3 Still Required, Very Limited Reporting Extension (Updated)

While HUD’s Offices of Public and Indian Housing (PIH) and Community Planning and Development (CPD) have provided a number of waivers and flexibilities for the Public Housing program, Housing Choice Voucher program, HOME Investment Partnership program, Community Development Block Grant, and Continuum of Care (CoC) program, HUD’s Office of Fair Housing and Equal Opportunity (FHEO) has not waived any of the Section 3 statutory and regulatory requirements.

[Updated Text Begins] On April 17, 2020, FHEO released updated Frequently Asked Questions (FAQ) About the Coronavirus Disease (COVID-19) for Section 3 Covered Recipients which addresses 13 questions on how COVID-19 affects Section 3 compliance. Question 2 specifically asks “Are Section 3 Compliance requirements waived during the virus condition?” and FHEO’s answer is “No, the Section 3 statutory and regulatory requirements have not been waived.” Updated questions are also asked about Section 3 SPEARS reporting requirements and deadlines. In response, FHEO states that the Section 3 reporting requirement is not waived and Public Housing Authorities (PHAs) and community development agencies have an extension until July 31, 2020. Additional extensions are not addressed in the updated FAQ but generally PHAs and community development agencies may request extensions beyond July 31, 2020 but must provide justification and any extension request will be reviewed on a case-by-case basis. [Updated Text Ends]

[Removed Text Begins] On April 3, 2020, FHEO released Frequently Asked Questions (FAQ) About the Coronavirus Disease (COVID-19) for Section 3 Covered Recipients which addresses 13 questions on how COVID-19 affects Section 3 compliance. Question 2 specifically asks “Are Section 3 Compliance requirements waived during the virus condition?” and FHEO’s answer is “No, the Section 3 statutory and regulatory requirements have not been waived.” Questions are also asked about Section 3 SPEARS reporting requirements and deadlines. In response, FHEO states that the Section 3 reporting requirement is not waived and Public Housing Authorities (PHAs) and community development agencies have an extension until June 1, 2020 but “must clearly demonstrate how COVID-19 precluded timely reporting.” PHAs and community development agencies may request extensions beyond June 1, 2020 but must provide justification and any extension request will be reviewed on a case-by-case basis.[Removed Text Ends]

FHEO has not waived or reduced the Section 3 requirements and reporting so PHAs and community development agencies must continue to create employment, training and contracting opportunities to Section 3 residents and Section 3 businesses. The Safe Harbor requirements have not been reduced either. PHAs and community development agencies should continue to hire staff and procure contracts, if possible, and if unable to meet the Safe Harbor requirements, they should document their efforts “to make every possible effort ‘to the greatest extent feasible’ to make employment and contracting opportunities available to” Section 3 residents.

NAHRO is relaying information from our members on the unprecedented operational and economic concerns affordable housing providers are facing to HUD and is requesting maximum flexibility for PHAs and community development agencies during the COVID-19 pandemic emergency.

NAHRO will continue to provide the latest information from HUD and Congress on the COVID-19 emergency response to our members and the public through our communication tools including the NAHRO coronavirus webpage and the NAHRO blog.

HUD Creates Online Guidance Portal

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.

Complimentary Webinar!! 2020 Census & PHAs – October 1, 2pm EDT

On Tuesday, October 1, at 2pm eastern time, NAHRO will be hosting a complimentary webinar in preparation for the 2020 Census. Below is information on the session and the registration link. This session is for agencies of all sizes from the smallest to the largest and will discuss the 2020 Census and the interaction between Census and PHAs including first-hand PHA experiences.

2020 Census Key Partnership – Public Housing Authorities

The 2020 Census is right around the corner. The U.S. Census Bureau and Public Housing Authorities are working together to make sure every person will be counted. During this webinar you will hear from Carol Gore of the Cook Inlet (Alaska) Housing Authority and John Mahon of the Bayonne (New Jersey) Housing Authority. Carol and John will share their experiences working with the U.S. Census Bureau in addition to employment opportunities for PHA residents. Join us and bring all your 2020 Census questions!

Please register for 2020 Census Key Partnership – Public Housing Authorities on Oct 1, 2019 2:00 PM EDT at:

 https://attendee.gotowebinar.com/register/7438435157680047371?source=blog

After registering, you will receive a confirmation email containing information about joining the webinar.

New RAD Notice, Revision 4 Released

Earlier today, HUD released the new Rental Assistance Demonstration (RAD) notice: “Rental Assistance Demonstration – Final Implementation, Revision 4” (Notice H-2019-09; PIH-2019-23 (HA)). The RAD program allows for units to be converted from certain Department of Housing and Urban Development (HUD) funding streams, such as public housing, to either a Section 8 project-based voucher (PBV) funding stream or a Section 8 project-based rental assistance (PBRA) funding stream. There are several major changes in this notice, including changes to the First Component of RAD (which allows public housing units to be converted to PBV or PBRA) and implementation of the 2018 Appropriations Act provision allowing Section 202 project rental assistance contracts (PRAC) to be converted to PBV or PBRA.

The changes to the First Component of RAD include the following:

  • A policy that RAD rents will be updated every two years (RAD awards after each update will use the updated rents);
  • A newly added “Concept Call” step to the RAD process, to allow PHAs to receive confirmation that project plans are sufficiently advanced to submit a Financing Plan;
  • More stringent notice requirements for residents in developments to be converted (the new notice details resident participation requirements at each step of the RAD process);
  • A policy that all households residing in regular PBV units will have the same resident rights extended to them as households that reside in RAD-PBVs in converted developments;
  • A mechanism for PHAs to enter into partnerships with each other to convert developments;
  • A policy allowing for rent increases in certain scenarios for PBRA conversions, such as developments located in Opportunity Zones;
  • Elimination of the requirement to submit the Capital Needs Assessment (CNA) tool in certain scenarios; and
  • Other changes (including changed requirements for portfolio awards, a change in how PHAs report debts owed, and broadening the use of “tiered environmental reviews”).

At this time, NAHRO staff are still reviewing the new notice. Additional analysis will be provided in future NAHRO publications.

The RAD Notice, Revision 4 can be found here.

[2:17 pm edit – The new notice can also be found on HUD’s RAD website here.]

Family Unification Program (FUP) Voucher Webinar to be hosted by CSH and CLPHA

Our friends at the Corporation for Supportive Housing (CSH) and the Council of Large Public Housing Authorities (CLPHA) are hosting a webinar on how to effectively use Family Unification Program (FUP) vouchers. The webinar is aimed at PHAs, public child welfare agencies, and homelessness response system partners. The webinar will provide an overview of the program in general, discuss the new notice of funding availability ($30 million; applications due 7/24/18), and provide recommendations and examples from the field.

The webinar will take place on Wednesday, May 16 at 12 pm ET.

Registration for the webinar can be found here.

HUD Extends Section 3 “Past Due” Reporting Deadline to December 31, 2017

HUD has revised the July 7, 2017 SPEARS Update that set a reporting deadline of July 31, 2017 for “past due” (2013, 2014, 2015, 2016, & some 2017 report years) reports.

On August 14, 2017, HUD issued a SPEARS Update that extended the reporting deadline for “past due” reports to December 31, 2017. The SPEARS Update is available at https://portal.hud.gov/hudportal/documents/huddoc?id=PHAReportDue8-14-17.pdf.

HUD’s Section 3 office is also aware of issues in submitting adjusted reports (6, 9, or 15 month reports) due to the reporting year switching to the PHA fiscal year. It is anticipated that HUD will update the SPEARS system to correct this issue in the very near future.

More information on Section 3 reporting is available at https://portal.hud.gov/hudportal/HUD?src=/program_offices/fair_housing_equal_opp/section3/section3/spears.