I have received word from a HUD official that the Housing Choice Voucher (HCV) Forecasting Tool has been updated. The forecasting tool provides the means to successfully plan and manage a voucher program. The tool has been updated with the final funding numbers for 2018, as well as reconciled 12/31/2017 Restricted Net Position (RNP) numbers for most PHAs.
Additionally, the tool has been updated with several new features:
- the ability to automatically populate PIC EOP report information;
- the ability to incorporate different success rates and time from issuance to HAP rates depending on the voucher type;
- the ability to quickly move information from an old tool to a new tool on the Success Rate Tracker Tab; and
- a better method for estimating potential offset numbers, based on HUD’s most recent offset-calculating methods.
The tool can be accessed from HUD’s Office of Housing Choice Vouchers webpage.
Earlier today, HUD’s Office of Recapitalization sent a RADBlast! email announcing the publication of a Frequently-Asked-Questions (FAQ) document about using HUD’s new demolition and disposition notice–PIH 2018-04 (HA)–in conjunction with the Rental Assistance Demonstration (RAD) program.
Specifically, the document answers questions around the provision in the demolition and disposition notice that allows PHAs to convert at least 75 percent of public housing units in a project under RAD–which meet the requirements of the RAD Final Implementation Notice REV-3, H-2017-3–and to convert through disposition up to 25 percent of public housing units within the project to Section 8 project-based voucher assistance.
For those contemplating completing a RAD transaction, this provision is another tool to help finance the deal.
The RAD-Section 18 Blend document can be found at the RAD Resource Desk or here.
On Monday, June 4, HUD held a UPCS-V Information Technology (IT) Summit. During the session, HUD Inspection Standards and Data for Vouchers (ISDV), presented brief welcoming remarks, an overview of where we are in the protocol development process (29,132 inspections conducted; 170 PHAs trained by April; and 247 participating PHAs), described the protocol; described the decision trees; and provided a technical overview of VEDGA.
During the session, HUD also mentioned that a beta version of the UPCS-V protocol would soon be publicly available. Yesterday, HUD published the beta version of the UPCS-V protocol. Changes in the new version of the protocol are based on three guiding principles: simplicity, transparency, and meeting the objective of national housing policy (i.e., aligning with UPCS). Specific changes include the following:
- An addition of a glossary;
- An updated life threatening or emergency (LTE) deficiencies list;
- Inclusion of carbon monoxide as an inspectable item;
- Fifty-three percent decrease in length;
- The alphabetization of the defect dictionary; and
- An overall reorganization of the document to provide information clearly.
Input and feedback on this version of the protocol can be given at ISDV@hud.gov.
HUD is specifically seeking feedback on the following:
- Should there be additional terms added to the glossary?
- Is the order or the protocol logical and does it meet inspector needs?
- Is there anything missing from the protocol that a novice inspector might need?
The slides from the HUD UPCS-V IT session can be found here.
The beta UPCS-V protocol can be found here.
On Thursday, May 17 and Friday, May 18, HUD held a training on the Rental Assistance Demonstration (RAD) program titled “Keys to A Successful RAD Conversion.” The two day long sessions were held in the Brooke-Mondale Auditorium at HUD’s Headquarters. The training was targeted at PHAs that had not yet contemplated, or had not yet started, a RAD transaction and was meant to provide information about the RAD process. The Department had previously promised to post videos of each of the sessions, which they recently did. The session videos can be found below.
Click below to see each session.
Earlier today, PHA Executive Directors received an email announcing that HUD has published a webinar going over the contents of the 2018 Housing Choice Voucher (HCV) Program Implementation notice. The webinar can be found below. Questions about the notice or webinar can be sent to PIH.Financial.Management.Division@hud.gov.
The webinar can also be found here.
Today, HUD has posted a pre-publication copy of a notice titled “Section 8 Housing Assistance Payments Program – Fiscal Year 2018 Inflation Factors for Public Housing Agency Renewal Funding.” This notice informs the public of the publication of Renewal Funding Inflation Factors (RFIFs), which are the inflation factors applied to the Housing Choice Voucher (HCV) Program renewal funding that adjusts the funding amount of individual PHAs to take into account changes in rents, utility costs, and tenant incomes.
The notice also notes that the methodology for the Fiscal Year (FY) 2018 factors is the same as the FY 2017 factors, but requests comments on whether this should be changed. In particular, the notice requests feedback on whether the current practice of incorporating local rent surveys used to change FMRs into the calculation of RFIFs should continue. Comments will be due 30 days after this notice has been published in the Federal Register.
The FY 2018 RFIFs, when posted on Wednesday (5/30/18), will be found here.
The pre-publication copy of the notice can be found here.
[5/30/18 Edit – Comments are due June 29, 2018. The full published notice can be found here.]
[6/11/18 Edit – HUD has extended the comment deadline for this notice to July 6, 2018. The pre-publication copy of the extension can be found here.]
Yesterday, HUD published notice PIH 2018-09, titled “Implementation of the Federal Fiscal Year (FFY) 2018 Funding Provisions for the Housing Choice Voucher Program.” This notice provides information about the Housing Choice Voucher (HCV) Program implementation in 2018. Topics in this notice include calculation of calendar year (CY) 2018 Housing Assistance Payments (HAP); $75 million of HAP set-aside funding; tenant protection vouchers; funding for administrative costs; special-purpose vouchers; and other topics.
The notice also provides a brief summary of FY 2018 HCV account totals (for additional coverage, please see NAHRO’s Section 8 coverage of the FY 2018 Omnibus budget bill [members only]):
- HAP Renewal Funding – $19.6 billion;
- Tenant Protection Vouchers (TPV) – $85 million;
- Administrative Fees (both Ongoing and Additional) – $1.76 billion;
- Mainstream Program – $505 million;
- Tribal HUD-VASH renewals – $5 million;
- HUD-VASH vouchers – $40 million; and
- Family Unification Program – $20 million.
For additional information, please click below.
On May 15, the House Appropriations Transportation, Housing and Urban Development (T-HUD) Subcommittee released its draft FY 2019 appropriations bill. Overall, the bill received an additional $1.5 billion increase to its allocation compared to FY 2018, an achievement considering several spending bills have been level funded and T-HUD was expected to have a similar fate. A summary is below; NAHRO will release a more detailed analysis soon.
The FY 2018 omnibus bill marked the first significant increase to HUD funding in nearly a decade; NAHRO and its members should be proud that the House bill preserves many of those funding increases in a highly competitive appropriations season.
Most programs within HUD received level funding or a slight increase, with the unfortunate exception of the HOME Investment Partnerships program. HOME was cut by 12 percent compared to FY 2018.
- Public Housing Capital Fund: $2.75 billion, level funding – including a new $30 million set-aside for competitive grants for the demolition of the most distressed public housing units
- Public Housing Operating Fund: $4.55 billion, level funding
- Choice Neighborhoods:$150 million, level funding
- Section 8 Housing Assistance Payment Renewals:$20.107 billion, a 2.6 percent increase
- Mobility Demonstration: $50 million for a new mobility demonstration program
- Ongoing Administrative Fees: $1.73 billion, level funding
- Family Self-Sufficiency: $75 million, level funding
- Section 8 Project-Based Rental Assistance: $11.747 billion, a 2 percent increase
- Community Development Block Grant:$3.3 billion, level funding
- HOME Investment Partnerships:$1.2 billion, a 12 percent decrease
- Housing Opportunity for Persons with AIDS:$393 million, a 5 percent increase
- Homeless Assistance Grants:$2.546 billion, a 1 percent increase
As the FY 2019 appropriations process moves forward, NAHRO will focus advocacy efforts on the HOME program to ensure that the cuts proposed by the House are not enacted. NAHRO will also advocate for increased funding and flexibility for HCV Administrative Fee funds as level funding does not take into account the addition of new vouchers and the increased need for resident opportunity resources.
The bill will be brought before the House T-HUD Subcommittee on May 16 for consideration. No amendments are expected. It’s likely that the full House Appropriations Committee will vote on the bill next week. The timeline for a floor vote is unclear, though Congress typically tries to move as many bills through the process as possible before the August recess.
The Senate T-HUD bill is expected to be considered before the Senate T-HUD Subcommittee during the week of June 4.
Recently, the Center on Budget and Policy Priorities and the Poverty and Race Research Action Council published a Small Area Fair Market Rent (FMR) implementation guide titled “A Guide to Small Area Fair Market Rents (SAFMRs): How State and Local Housing Agencies Can Expand Opportunity for Families in All Metro Areas.” The guide provides background on Small Area FMRs–which are FMRs that are calculated over zip codes instead of broader metropolitan areas to incentivize the deconcentration of poverty in metropolitan areas–as well as advice to PHAs on how to effectively implement them.
For those PHAs that are already familiar with HUD’s Guidance on Small Area FMRs and HUD’s Implementing Small Area FMRs Guidebook, there are still some new ideas in this guide. For example, this guidebook notes that to protect families in low-rent zip codes, which will see a decline in FMR, a PHA may apply a portion of the reduction and then hold families harmless after the initial reduction. A footnote helpfully explains that though this option is “not mentioned in HUD’s notice or guidebook . . . [it] is permitted by the applicable regulation. 24 C.F.R. § 982.505(c)(3)(ii) [Hyperlink added].”
The CBPP and PRRAC Small Area FMR Implementation Guide can be found here.
Earlier today, three groups (the National Fair Housing Alliance [NFHA], the Texas Low Income Housing Information Service, and Texas Appleseed) filed a complaint in Federal Court (the United States District Court for the District of Columbia) against HUD regarding its recent actions to extend the deadline for local governments to submit their Assessments of Fair Housing (AFHs).
The complaint states that HUD “published a three-page notice . . . suspending the key requirements of the [Affirmatively Furthering Fair Housing (AFFH)] rule” (HUD characterizes this action as an “Extension of Deadline for Submission of Assessment of Fair Housing for Consolidated Plan Participants“). The action caused “irreparable and ongoing injury” for the three groups suing. As a result of HUD’s action, Texas Appleseed and the Texas Low Income Housing Information Service will have to “divert [mission-critical] resources” to “remedying the effects of [HUD’s] actions.” Additionally, NFHA will have to “divert resources to assisting its members around the country . . . to combat the effects of [HUD’s] actions.”
The groups believe that HUD erred in three ways. First, “[b]y failing to engage in notice-and-comment rulemaking before delaying and altering the AFFH Rule, HUD failed to observe procedures required by law, in contravention of the [Administrative Procedure Act].” Second, “HUD’s delay of the Rule is arbitrary, capricious, or an abuse of discretion, in contravention of the [Administrative Procedure Act]” because HUD’s rationale for extending the deadline (inadequate technical assistance among other reasons) does not explain why HUD cannot improve its technical assistance or why it is acceptable to go back to the previous regulatory framework (i.e., the Analysis of Impediments). Third, “HUD’s effective suspension of the AFFH Rule violates the Fair Housing Act, in contravention of the [Administrative Procedure Act].” Here, the complaint states that HUD is violating its own “affirmative obligation under the Fair Housing Act to ensure that federal housing programs are administered, and federal housing funds spent, in a manner that furthers fair housing.”
The complaint asks that the Court do five things. First, enter a declaratory judgment that HUD’s action is “arbitrary, capricious, an abuse of discretion or contrary to law, and without observance of procedure required by law.” Second, issue preliminary and permanent injunctions requiring HUD to suspend its notice extending the deadline for submission of AFHs for local governments and implement and enforce the requirements of the AFFH rule moving forward. Third, direct HUD to take affirmative steps to remedy the harms caused by the extension. Fourth, award the groups attorney’s fees and costs. Fifth, award any other relief that may be “just and equitable.”
The full complaint can be found here.