Despite the challenges posed by COVID-19, NAHRO remains committed to connecting you with industry leaders and important perspectives. In lieu of our cancelled Washington Conference, we’re thrilled to invite you to a virtual convening on Monday, March 30, from 12:30 p.m. – 2:30 p.m. eastern time with two very special guests:
• Dr. Raphael Bostic, the President of the Federal Reserve Bank of Atlanta, will give a presentation on Inclusive Economic Development: Lessons and Challenges, and take questions from attendees; and
• Dr. Mark Calabria, Director of the Federal Housing Finance Agency, will discuss FHFA’s mission, its role in the housing sector, and his thoughts on critical milestones ahead.
This virtual convening is a complimentary benefit for NAHRO members, and reasonably priced for non-members. We look forward to connecting with you!
Public Charge Alert – “[The United States Citizenship and Immigration Services (USCIS)] encourages all those, including aliens, with symptoms that resemble Coronavirus Disease (COVID-19) (fever, cough, shortness of breath) to seek necessary medical treatment or preventive services. Such treatment of preventive services will not negatively affect any alien as part of a future Public Charge analysis.”
All of this information and additional information can be found at NAHRO’s Coronavirus page. It is accessible to non-members and members and can be found here.
Participants do not need to register in advance, but it is strongly recommended that they join the session 15 minutes in advance of the start time (1:45 pm ET).
To join the session (at the appropriate time) click here.
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.
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.
Earlier today, HUD sent an email with links to fact sheets from the Centers for Disease Control and Prevention (CDC) about COVID-19 (popularly known as the coronavirus). The Department encourages PHAs to make the fact sheets available to their program participants. The fact sheets are listed below:
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.
The NAHRO Blog: Legislative & Policy Updates from Washington, DC 