Section 8

UPCS-V Version 1.5 Released

~ Tushar Gurjal ~ Leave a comment

 

upcs-vver1-5logo

HUD REAC’s Oversight and Evaluation Division (OED) has released Version 1.5 of the UPCS-V protocol. NAHRO is still in the process of reading through it, but will continue to provide our membership with additional information and updates on both the UPCS-V protocol and the Demonstration testing the inspection protocol. HUD is seeking feedback at OED@hud.gov.

The protocol can be found on OED’s homepage or can be directly accessed here.

Our prior coverage of the UPCS-V protocol Version 1.0 can be found here. (Members only.)

HUD Publishes Lead-Based Paint Proposed Rule

~ Tushar Gurjal ~ Leave a comment

(9/6/16 Update: The published Federal Register notice can be found here. Comments are due by October 31, 2016.)

Tomorrow, HUD will publish its lead-based paint proposed rule titled “Requirements for Notification, Evaluation and Reduction of Lead-Based Paint Hazards in Federally Owned Residential Property and Housing Receiving Federal Assistance; Response to Elevated Blood Lead Levels” in the Federal Register. While NAHRO is still in the process of doing a deeper dive into the proposed rule, here are some of the core requirements being proposed.

  • Program Scope –  The proposed rule will apply to the following 5 sets of programs:
    • Project-Based Assistance Provided by non-HUD Federal Agencies;
    • Project-Based Assistance;
    • HUD-owned and Mortgagee-in-Possession Multifamily Property;
    • Public Housing Programs; and
    • Tenant-Based Rental Assistance.
  • Effective Date –  HUD is considering an effective date of 6 months after publication of the final rule, but is also looking at time periods of either 1 year or 1 month.
  • Elevated Blood Lead Level –  The rule proposes to revise the Lead Safe Housing Rule (LSHR) to adopt the Centers for Disease Control and Prevention’s (CDC’s) approach to establishing a blood lead level for which the CDC recommends environmental intervention. Currently, CDC guidance defines Elevated Blood Lead Level (EBLL) in children under age 6 to be “based on the blood lead level equaled or exceeded by 2.5 percent of U.S. children aged 1 – 5 years.” The current reference range level is 5 or more micrograms per deciliter of lead in the blood. As the CDC is “tying the reference value to the national distribution of blood lead levels, the reference level will continue to decrease whenever progress is made on reducing childhood lead exposure.”
  • Inspection, Evaluation, and Control Activities –  Depending on the program, lead-based paint inspections, inspections for deteriorated paint, and risk assessments including dust-wipe sampling and soil sampling may be required.
  • Abatement Measures –  Public Housing must perform abatement measures to eliminate lead-based paint or lead-based paint hazards during comprehensive modernization.
  • Interim controls and Paint Stabilization –  Depending on the program, additional interim controls (measures designed to reduce temporarily human exposure or likely exposure to lead-based paint hazards) or paint stabilization (repairing physical defects and applying a new coating of paint) may be required.
  • Response to Young Children with Elevated Blood Levels –  If a child under 6 has an elevated blood lead level, the owner or other entity must follow a designated protocol (same for all programs, except non-HUD project-based assistance, for which it is narrower) including:
    • Conducting an environmental investigation;
    • Conducting interim control – measures designed to reduce temporarily human exposure or likely exposure to lead-based paint hazards;
    • Controlling other housing-related sources of lead exposure; and
    • Encouraging occupants to address other non-housing related lead exposure sources.
  • Other units –  If the unit where the child resides is in a building or development with other assisted dwelling units covered by the rule, the owner or other entity must provide documentation to the HUD field office that the owner or other entity has complied with the evaluation requirements. If there is no documentation of compliance with the evaluation requirements, the owner or other entity must conduct a risk assessment and conduct interim controls or conduct a visual assessment and paint stabilization–depending on the program.
  • Comments –  HUD has 4 questions for comment each with subparts.

NAHRO will continue to read and analyze this rule and will provide additional, deeper coverage to its members. Comments will be due 60 days after publication in the Federal Register.

The pre-publication proposed rule can be found here.

HUD’s Press Release on the rule can be found here.

HUD Publishes FY 2017 SAFMRs

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HUD has published their FY 2017 Small Area Fair Market Rent (SAFMR) tables. They were not initially published when the other FY 2017 FMRs were published.

They can be found at HUD PD&R’s SAFMR webpage or accessed directly here.

Read about NAHRO’s views on HUD’s proposed SAFMR rule here.

Read about the FY 2017 FMR Federal Register notice here.

Updated HCV Forecasting Tool and Payment Standard Tool

~ Tushar Gurjal ~ Leave a comment

I received an e-mail from a HUD official asking that I make sure that our membership is aware of the following updates to HUD’s Housing Choice Voucher (HCV) Program Projection Tools:

  • HCV Two-Year Forecasting Tool: According to HUD, “[t]he objective of the Two-Year Tool (TYT) is to analyze a PHA’s utilization situation, which includes running basic leasing and spending scenarios to better inform decisions going forward in an effort to optimize the program over a multi-year period.” The Two-Year Tool has been updated so that it can be accessed by any individual with a HUD Web Access Security System (WASS) username and password. A new feature in this update is that when accessing the tool with WASS credentials, all “PHAs can now populate and create a Two-Year Tool on their own . . . [by entering] their PHA code and [clicking] the ‘Open and Populate Two-Year Tool’ button.” HUD notes that “[s]ome program variables are populated with default values (e.g. success rate, time from issuance to HAP); these should be updated as appropriate.”
  • Payment Standard Tool (new): “[T]he Payment Standard Tool (PST) is [used] to analyze a potential payment standard change of both program participants’ rent burdens and the PHA’s program costs.” Like the Two-Year Forecasting Tool, the Payment Standard tool can be accessed with WASS credentials (i.e., a username and password).

HUD plans to release YouTube videos in the near future to walk users through using these tools.

Descriptions of the tools can be found on the Office of Housing Choice Vouchers webpage here.

Both tools mentioned above (as well as a “HCV Two-Year Tool Guide” and a “Success Rate Guide”) can be accessed here.

FY 2017 FMRs Published

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HUD has published its FY 2017 FMRs on its website. While we are still in the process of going through the notice announcing the publication of the FMRs, here are some of the main takeaways:

  • After the passage of the Housing Opportunity Through Modernization Act of 2016 (HOTMA), HUD is no longer required to publish FMRs in the Federal Register, but may now publish them on its website, while announcing the postings in the Federal Register.
  • After HOTMA, FMRs shall be effective no earlier than 30 days after the date of publication of the announcement notice in the Federal Register.
  • HOTMA requires that HUD publish proposed “material changes” to the methodology for comment. The notice asks for public comment on “defining the scope of material changes that will trigger notice and comment in future calculations of FMRs.”
  • The methodology for calculating the FY 2017 FMRs will remain the same as the methodology used to calculate the FY 2016 FMRs, except that updated data will be used.
  • There are no geography changes, but “several areas have been renamed to avoid confusion.”
  • The effective date of the FMRs will be October 1, 2016.
  • HUD has established a procedure “for PHAs and other interested parties to comment on such fair market rentals and to request, within a time specified by [HUD], reevaluation of the fair market rentals in a jurisdiction before such rentals become effective.”

Read the full pre-publication notice here.

[8/26/16 UPDATE: The Federal Register publication can be found here. Comments are due by September 26, 2016.]

The FY 2017 FMRs can be found here (scroll to FY 2017). The PDF tables can be found here.

Assessment of Fair Housing Tool for Local Governments with Proposed Changes Now Available

~ Jenny Hsu ~ Leave a comment

As NAHRO previously reported, on August 23, HUD published a 30-day Notice in the Federal Register seeking additional public feedback on the proposed changes to HUD’s Affirmatively Furthering Fair Housing (AFFH) Local Government Assessment Tool (Local Government Tool). The Local Government Tool is the standardized tool that communities receiving HUD Community Planning and Development (CPD) formula grant dollars must use to conduct and submit their Assessments of Fair Housing (AFH).

The 30-day Notice proposes a number of additions to the Local Government Tool that would, ideally, help simplify the AFH process for Qualified Public Housing Authorities (QPHAs), defined as PHAs not designed as “troubled” with a combined unit total of 550 or less, and for local governments receiving small CPD formula grants. The tool would include two new sections for streamlined assessments for QPHAs and small local governments, called “inserts.”  QPHAs and local governments seeking to fulfill their Fair Housing requirements through these streamlined “inserts” must be involved in a joint or regional collaboration with a local government as the lead entity.

The proposed Local Government Tool with the new “inserts” is now available for public viewing on  HUD Exchange. The deadline to respond to the 30-day Notice and comment on the Local Government Tool is September 22, 2016.

HUD-VASH Second Round Funding Announced

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Yesterday, HUD and the United States Department of Veterans Affairs (VA) announced a second round of HUD-VASH funding. HUD-VASH combines vouchers from HUD with case management and clinical services provided by VA. Since 2008, more than 79,000 vouchers have been awarded. This round of funding provides 108 vouchers and $871,056 worth of funding.

A list of PHAs that have been awarded HUD-VASH vouchers can be found at HUD’s press release here.

HUD Announces Changes to the AFFH Assessment Tools for Small PHAs and Local Governments

~ Jenny Hsu ~ Leave a comment

On August 23, HUD will publish a 30-day notice in the Federal Register seeking public feedback on the Local Government Assessment Tool, the instrument with which communities receiving HUD Community Planning and Development (CPD) formula grant dollars must use to conduct and submit their Assessment of Fair Housing (AFH) analysis, as required by the Affirmatively Furthering Fair Housing (AFFH) Final Rule.

Due to limited staff and resources, NAHRO has long-requested for HUD to streamline the AFFH assessment tools for small program participants. The 30-day Notice announces two substantial changes that would, ideally, help simplify the AFH process for Qualified Public Housing Authorities (QPHAs), defined as PHAs not designed as “troubled” with a combined unit total of 550 or less, and for local governments receiving small CPD formula grants:

  • HUD seeks to revise the existing Local Government Assessment Tool to include two new streamlined assessments for small program participants, called “inserts.” The first insert would be for use by QPHAs and the second insert would be for use by local governments that received a CBDG grant of $500,000 or less in the most recent fiscal year prior to the AFH due date. QPHAs and local governments seeking to fulfill their AFFH requirements through these streamlined inserts must be involved in a joint or regional collaboration with a local government as the lead entity.
  • HUD seeks to issue a fourth assessment tool for Qualified PHAs. Prior to this notice, HUD had committed to issuing only three AFFH assessment tools (Local Government, State and Insular Areas, and PHA-only). The new QPHA Assessment Tool would be for use by a QPHA or by multiple QPHAs jointly collaborating to submit an AFH. HUD assumes that many QPHAs will want to take advantage of this option, particularly those unable to enter into a joint or regional collaboration with another partner. HUD intends to issue a separate public notice and comment process for this new tool.

The 30-day notice also addresses the public comments received in response to the 60-day information collection notice that was published on March 23, 2016 (see NAHRO’s comments here). NAHRO’s next issue of The Monitor (members only) will have additional details about the contents of the 30-day notice.

GAO Publishes Report on HUD Management

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On August 19, the United States Government Accountability Office (GAO) made publicly available a report it wrote for congressional requesters. The report found that HUD has “not consistently incorporated requirements and key practices  identified by GAO to help ensure effective management into its operations.”

The report identified five management functions and discusses how completely HUD implemented prior GAO recommendations. Selected excerpts can be found below:

Performance planning and reporting – “HUD met most of the requirements in the GPRA Modernization Act of 2010 for its strategic plan and annual performance plan and report . . . [b]ut HUD’s strategic plan does not clearly link HUD’s goals and objectives with federal priority goals.”

Information technology management – “HUD has not demonstrated that it has the capacity to effectively plan for and manage IT projects.”

Human capital management – “HUD has made progress in developing new human capital plans and mostly followed key principle and practices for strategic workforce planning, succession planning, and training planning.”

Financial management – “HUD did not follow seven of eight key practices for financial management.”

Acquisition management – “HUD partially followed key practices for acquisition relating to organizational alignment and human capital.”

The report recommends that HUD take the following eight actions:

  1. Link HUD’s goals and objectives with federal priority goals;
  2. Describe why HUD’s goals were not met and HUD’s plans for achieving them;
  3. Establish procedures and time frames to reach out to Congress and stakeholders to ensure that the strategic plan meets statutory requirements;
  4. Establish a process and schedule to review and update HUD’s human capital strategic plan; strategic workforce plan; and succession plan;
  5. Establish a process and schedule to update policies and procedures to help ensure that policies and procedures for key management functions remain current and complete;
  6. Formalize lines of communication between the Chief Information Officer and the agency head;
  7. Designate entities within program offices for fraud risk management activities; and
  8. Develop written policies for conducting program evaluations.

Thanks to PHADA for bringing this report to our attention.

The full report can be found here. The PDF can be found here.

The highlights page can be found here.