Section 8

HUD Extends AFH Deadline for Local Governments

~ Tushar Gurjal ~ 2 Comments

Tomorrow, HUD will publish a notice in the Federal Register titled “Affirmatively Furthering Fair Housing: Extension of Deadline for Submission of Assessment of Fair Housing for Consolidated Plan Participants.” The notice states that for local government consolidated plan participants, the deadline for submitting their Assessment of Fair Housing (AFH) will be extended to the next AFH submission date after October 31, 2020. Although the notice will be effective immediately after publication in the Federal Register, HUD is inviting public comment for 60 days on the extension. [1/5/18 Edit – Comments are due by March 6, 2018.]

The notice extends the deadline for submission of an AFH to all local government consolidated plan program participants to the AFH submission deadline after October 31, 2020. Local governments that qualified for a previous extension under a October 24, 2016 notice are also covered under this extension. All local government program participants must still comply with the statutory obligation of affirmatively furthering fair housing.

Until a consolidated plan program participant is required to submit an AFH, it will continue to provide the AFFH Consolidated plan certification in accordance with requirements that existed prior to August 17, 2015. These requirements obligated a program participant to certify that it would affirmatively further fair housing by conducting an Analysis of Impediments (AI) to fair housing choice within the jurisdiction and take action to overcome the effects of the identified impediments.

For program participants starting a new 3 to 5 year consolidated plan cycle, the AI should continue to be updated until those consolidated plan program participants submit an AFH after October 31, 2020. Program participants that have already submitted an AFH which has been accepted by HUD must continue to execute the goals of that AFH (they are not required to perform an additional AI). Program participants that received a non-accept decision should not submit their revised AFHs. HUD will discontinue the review of AFHs currently under review and will not render an accept, deemed accepted, or non-accept determination.

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HUD Sends Email on Revocation of Small Area FMR Suspension

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On Friday, December 29, HUD sent an email stating that a Federal Court has set aside the Small Area FMR Suspension. The suspension, citing harm to vulnerable households, would have delayed the implementation of Small Area FMRs until 2020. The email states that “PHAs must immediately take all steps necessary with respect to dedicating monetary and human resources towards the implementation; as well as integrating the new FMR requirements in any planning the PHA conducts. As expeditiously as possible, HUD will issue guidance addressing implementation issues, technical assistance, and potential obstacles to implementation.”

NAHRO is in the process of working with HUD to help implement Small Area FMRs for those members who must now use them.

PUC Automatic Trending Now Included in HCV Forecasting Tool

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A HUD official emailed us to let us know that the Housing Choice Voucher (HCV) Forecasting tool has again been updated. This time, the tool includes an automatic trending of per unit costs (PUC) in years 1 and 2. Users may still adjust this trend depending on the on-the-ground circumstances. This change was made because “in 2017 as PUCs have gone up more around the nation, may PHAs have not accounted for the trend in future months, leading to shortfalls.”

The HCV forecasting tool can be accessed here.

HUD Sends HCV Funding “Get Ready” Letter

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Earlier today, HUD’s Financial Management Center sent a letter informing PHAs of potential funding scenarios for Calendar Year (CY) 2018. The letter stated that the federal budget is currently being governed by a Continuing Resolution (CR) until Jan. 19, 2018. At that time, Congress may pass a budget or a year-long CR. The letter uses the amounts allocated for Housing Assistance Payments (HAP) and Administrative Fees in the House and Senate appropriations bills to estimate prorations for 2018. These estimations can be found in the table below.

Senate bill (S. 1655) House bill (H.R. 3353)
Administrative Fee 76.153% 70.233%
Housing Assistance Payments (HAP) 98.810% 95.301%

HUD notes that the proration levels were calculated by “estimating the full HCV program need for 2018 and comparing the program need to the available funding.” HUD recommends that PHAs assess their projected leasing and spending by modeling both scenarios. HUD also recommends using the forecasting tool.

The full letter can be read here (in Word format).

[12/28/17 Edit – HUD FMC sent another letter with an alternative link to the tool (if you were having trouble with the link above).]

HCV Forecasting Tool Now Incorporates Inflation Factor for 2018

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A HUD official emailed us to let us know that the Housing Choice Voucher (HCV) Forecasting tool now includes an estimated inflation factor for 2018. A PHA forecasting HAP for next year using the tool can now use both an estimated Housing Assistance Payment (HAP) proration (the default proration set for 2018 is 96%; it can be changed to model different scenarios) and an estimated inflation factor (the inflation factor is estimated to be 2.05% for 56% of PHAs). Setting a proration to 96% and using an inflation factor of 2% is equivalent to a 98% proration using the tool before this revision.

The HCV two-year tool can be accessed from HUD’s Office of Housing Choice Vouchers website.

HUD Announces FY 2017 FSS Awards

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On Friday, December 15, HUD announced $75 million in awards for the Family Self-Sufficiency (FSS) program for the public housing, housing choice voucher, and project-based rental assistance programs. Concurrently, HUD also marked the 25th anniversary of the FSS program.

“For 25 years, HUD and our local partners have been connecting residents to job training, childcare and other resources that expand their opportunities and lead them towards higher paying jobs and self-sufficiency” said Secretary Carson. From 2007 to 2016, the average household income of a FSS program participant increased from approximately $10,000 to $27,000 at the time of completion.

A list of the FY 2017 FSS grant awards can be found here.

HUD’s press release can be found here.

A document titled “25 Years of Family Self-Sufficiency Program: Families Working, Families Prospering” can be found here.

HUD Publishes Notice on Awarding Remaining HCV Set-Aside Funds for Portability

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Yesterday, HUD published notice PIH 2017-26 (HA) titled “Federal Fiscal Year 2017 Funding Provisions for the Housing Choice Voucher Program – Award of Remaining Set-Aside Funds.” The 2017 Appropriations Act provided $75 million of appropriated renewal funding for Prevention of Terminations Due to Insufficient Funding (Shortfall Funding); Unforeseen Circumstances; Portability Cost Increases; Project-based Vouchers; and HUD-VASH. While HUD originally anticipated using all $75 million for shortfall funding, HUD will now award approximately $15 million toward the portability cost increases category for initial PHAs located in a Major Disaster Declaration (MDD) area that was established between August 25, 2017 and December 31, 2017.

To be eligible for the funds, PHAs must be located in MDD areas and have experienced a significant increase in costs due to portability for tenant-based rental assistance. The Department will apply on behalf of non-operational PHAs in MDD areas that are listed as non-operational at the publication time of the notice. Other PHAs can submit requests for this additional funding through regular mail or email, but should not do both. HUD encourages applying electronically.

To apply, PHAs should fill out Attachment A of the notice and submit it to 2017Set-AsideApplications@hud.gov. The subject line should say the following: PHA Number, 2017 Portability Application.

The full notice can be found here.

HUD Publishes Webcast on HOTMA PHA Owned Units and PBV Provisions

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Last week, a HUD official emailed me a link to HUD’s Housing Opportunity Through Modernization Act of 2016 (HOTMA) webinar trainings on PHA Owned Units and Project-based Voucher provisions. These webcasts go over notice PIH 2017-21 (HA) titled “Implementation Guidance: Housing Opportunity Through Modernization Act of 2016 (HOTMA) – Housing Choice Voucher (HCV) and Project-based Voucher (PBV) Provisions.” If you have a little spare time this holiday weekend, it may be useful to watch them.

The trainings can be found here.

How Will MTW “Accommodate Regionalization”?

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On the Brookings website, there’s a joint post by Greg Russ, the Executive Director and CEO of the Minneapolis Public Housing Authority, and Robin Snyderman, a Nonresident Senior Fellow of Brookings’s Metropolitan Policy Program, which discusses the new Moving To Work (MTW) Expansion. The post focuses on the MTW expansion enabling legislation which allows HUD to “accommodate regionalization” in its MTW expansion plans.

What this legislative language specifically means is unclear, but the opportunity exists to use the MTW Expansion and its single-fund flexibilities to create a “a variety of public housing initiatives to operate in a regional market across agency boundaries.” Regional MTW approaches may be particularly relevant in Baltimore, Chicago, and the Twin Cities, where MTW agencies are located in high-poverty areas surrounded by other PHAs in lower-poverty jurisdictions.

In fostering a regional MTW approach, agencies will still need to properly balance the greater cost of mobility initiatives with the tradeoff of potentially serving fewer families. The post notes that one of the benefits of a regional MTW approach may be “the cost-savings associated with reduced administrative burdens of cross-jurisdictional activity.”

The post explores other concepts of what MTW regionalization may look like.

The entire post can be read here.

HUD Updates Disaster Portability Guidance

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Earlier today, HUD’s Financial Management Center sent additional guidance for PHAs receiving porting requests from program participants from Presidentially declared Major Disaster Declaration areas. Although previous guidance had been issued in an email, this guidance gives additional details on how receiving PHAs should process ports when the initial PHA is unable to complete portability requests.

This guidance applies to receiving PHAs that are contacted directly by families that are from areas covered by Presidentially declared Major Disaster Declarations and that wish to port, but have an initial PHA that cannot complete their portability responsibilities.

HUD has published a list, which includes all PHAs in Puerto Rico and the U.S. Virgin Islands, and whether receiving PHAs should use these alternative portability guidelines. HUD will continually update this list by 5 pm EST every Thursday to reflect changes that allow initial PHAs to resume portability operations. This disaster portability guidance will be in effect until January 31, 2018, unless HUD extends this date. Questions can be emailed to the HUD Disaster Portabilty Team at DisasterPortability@hud.gov.

The PHA Portability Status List can be found here.

HUD’s updated portability guidance can be found here.