Section 8

New Administrative Fee Formula Data Analysis Tool Posted

~ Tushar Gurjal

As we mentioned and summarized in our earlier post, HUD has published a revised version of the new administrative fee formula for the Housing Choice Voucher (HCV) Program. The proposed revision to the new administrative fee formula has now been officially posted to the Federal Register. Comments on the revision to the new administrative fee will be due on October 4, 2016.

HUD has also posted a new administrative fee formula data tool. By entering your PHA code, you can compare how much you would have been eligible for under the new formula to the actual amount you received in 2015. You can also adjust the proration for 2015 to create a more apples-to-apples comparison (i.e., compare full eligibility under the current formula to full eligibility under the revised new formula in Calendar Year 2015).

NAHRO will continue to analyze the new formula and bring you the latest analysis and updates.

You can find the new revision to the proposed administrative fee formula here.

You can find HUD’s PHA Admin Fee Tool 2015 here.

[Edit: We have now sent a Direct News item on the new proposed administrative fee formula (members only).]

HUD Publishes Revised New Administrative Fee Formula

~ Tushar Gurjal

HUD has published its revision of the new administrative fee formula for the Housing Choice Voucher Program. The new formula would calculate administrative fees on the basis of six variables:

  1. Program size;
  2. Wage rates;
  3. Benefit load;
  4. Percent of households with earned income;
  5. New admissions rate; and
  6. Percent of assisted households that live a significant distance from the PHA’s headquarters.

The PHA’s fees would be calculated yearly and then have a revised inflation factor applied to the calculated fee.

HUD has made three major changes to the prior formula:

  1. For PHAs in metropolitan areas, the wage index formula variable is based on the average local government wage rate for the PHA’s metropolitan Core Based Statistical Area (CBSA), rather than that average local government wage rate for all of the metropolitan counties in the PHA’s state;
  2. The health insurance cost index formula has been replaced with a new “benefit load” formula variable, which is designed to measure the variation in costs for all benefits that are paid for HCV employees, not just health insurance costs [In NAHRO’s comments we wrote the health insurance cost index metric does not “accurately (capture) all benefit costs” and recommended “(a) proxy that measures and takes into account these higher PHA costs”]; and
  3. The small area rent ratio (SARR) variable has been removed from the proposed formula [In NAHRO’s comments, we stated that “the small area rent ratio does not appropriately measure the actual costs of helping voucher holders to access high opportunity neighborhoods”].

NAHRO is still in the preliminary stages of analyzing the formula. Additional details and analysis will be forthcoming.

The full notice can be read here.

NAHRO’s comments on the previous formula can be read here.

HUD Awards $5 Million in Extraordinary Administrative Fees for HUD-VASH Program

~ Tushar Gurjal

Today, HUD published a list of forty-two PHAs that received a combined total of $5 million in extraordinary administrative fees for their HUD-VASH programs. Principal Deputy Assistant Secretary Lourdes Castro-Ramirez for Public and Indian Housing stated that “[t]hese housing authorities are going above and beyond in the movement to end veteran homelessness.”

The funds were awarded to agencies that are taking aggressive efforts in housing veterans. Activities that these agencies are performing and will continue to perform with these funds include marketing campaigns to recruit landlords; hiring temporary staff to provide housing search assistance; expediting document processing; inspecting units; issuing vouchers; and executing leases.

Read HUD’s full press release here.

NAHRO meets with HUD on Smoke-Free Rule and MTW Expansion; Briefing on SAFMRs

~ Tushar Gurjal

On June 29 and 30, NAHRO staff met with HUD staff to discuss the Moving to Work (MTW) Expansion that was included in the FY 2016 Omnibus and the upcoming smoke-free final rule. HUD also hosted a Small Area Fair Market Rent (SAFMR) proposed rule briefing.

Although HUD is still finalizing the MTW Expansion, they recently unveiled their MTW Expansion website, which contains information on the expansion process. HUD has also posted a MTW Expansion Frequently Asked Questions (FAQ) document.

According to HUD, a PIH notice should be published in the fall of 2016 soliciting applications for the initial cohort of new MTW PHAs. Additional cohorts of MTW PHAs will be added through separate notices through 2020 or until a total of 100 new MTW PHAs have been added. HUD has yet to determine the number of cohorts that will be included in the expansion nor specific policies to be tested through the expansion. The Secretary will weigh the advice of the MTW expansion advisory committee before determining both of these matters. For each cohort of new MTW PHAs, the specific policy proposals and methods of research and evaluation will be described in the PIH notice to be published in the fall of 2016. NAHRO’s policy proposals and recommended research evaluation methods for HUD regarding the MTW expansion can be found here (members only).

HUD plans to release the Instituting Smoke-Free Final Rule late summer or early fall. Although the rule is still undergoing the rule making process, NAHRO staff has learned HUD plans to submit the final rule to the Office of Management and Budget shortly. NAHRO was able to provide HUD staff with input on members concerns regarding the proposed rule. NAHRO’s comments on HUD’s proposed rule can be found here (members only).

HUD also hosted a briefing on the proposed SAFMR rule. The briefing went over the basics of the proposed rule and reviewed specific areas on which HUD was seeking comment. Comments and questions posed at the briefing from industry and advocacy groups included a question about the variability of all Fair Market Rents (FMRS) (to which HUD responded that they are working on a new methodology for FY 2017 FMRs); the current status of the SAFMR demonstration (it’s still going); and whether tenants who receive a subsidy cut in certain zip codes because of the SAFMR rule will be able to find housing in other zip codes because there are not enough available units or because landlords are not accepting vouchers (HUD does not know how to deal with this problem). Read our coverage of the proposed SAFMR rule here (members only).

 

Additional Information on Proposed Small Area FMR Rule from HUD

~ Tushar Gurjal

HUD has posted additional information on its new Small Area FMR rule titled “Establishing a More Effective Fair Market Rent (FMR) System; Using Small Area Fair Market Rents in Housing Choice Voucher Program Instead of the Current 50th Percentile FMRs.” HUD has posted a list of Frequently Asked Questions (FAQ) and a one page fact sheet.

Here’s an excerpt from the FAQ about HUD’s anticipated timeline:

What is the timeline for the Proposed Rule?
The federal rulemaking process is complex and seeking public input takes time. Hence, timing is not easy to predict. HUD’s hope would be to issue a final rule in 2016. The Proposed Rule is currently open for public comment.
Read the full FAQ here.
Read the fact sheet here.

HUD to Conduct Webcast on Small Area FMRs

~ Tushar Gurjal

HUD will conduct a webcast on its new proposed rule titled “Establishing a More Effective Fair Market Rent (FMR) System; Using Small Area Fair Market Rents in Housing Choice Voucher Program Instead of the Current 50th Percentile FMRs.” The briefing will take place on Thursday, June 30 2016, from 11 am to 12:30 pm EST. Previously, NAHRO has voiced concerns about the impact of SAFMRs on tenants, some of whom will have lower payment standards; on landlord participation rates; and on the administrative costs, among other concerns.

To register for the event, please click here.

NAHRO’s prior coverage of this rule can be found here. (Members only.)

AFH Submission Timeline Decision Tree Chart

~ Tushar Gurjal

Several members have requested a chart showing the timelines for Assessment of Fair Housing (AFH) submissions under the Affirmatively Furthering Fair Housing (AFFH) rule. Here is a decision tree chart that we came up with that we hope will simplify the process of figuring out the appropriate date an AFH is due. Please let us know if you have suggestions for how this chart can be improved or if you feel it is unclear.

HUD Publishes Names of Members of MTW Advisory Committee

~ Tushar Gurjal

On Wednesday, June 22, HUD published the names of the members of the MTW Advisory Committee. In its FY 2016 Appropriations bill, Congress directed HUD to expand MTW to include a hundred additional public housing agencies (PHAs) over the next seven years. Congress also called on HUD to establish a federal research advisory committee. The research advisory committee is responsible for advising HUD on specific policy proposals and methods of research and evaluation for MTW.

HUD has appointed the following people to the advisory committee:

  • Josh Meehan – Keene Housing;
  • Austin Simms – Lexington-Fayette Urban County Housing Authority;
  • Chris Lamberty – Lincoln Housing Authority;
  • Adrianne Todman – District of Columbia Housing Authority;
  • David Nisivoccia – San Antonio Housing Authority;
  • Janny Castillo – Former Resident of the Oakland Housing Authority;
  • Cindy Fernandez – Former Resident of the Housing Authority of Tulare County;
  • Asia Coney – Resident of the Philadelphia Housing Authority;
  • Larry Orr, Ph.D. –  Johns Hopkins University;
  • Heather Schwartz, Ph.D. – RAND Corporation;
  • Mark Joseph, Ph.D. – Case Western Reserve University;
  • Stefanie DeLuca, Ph.D. – Johns Hopkins University;
  • Jill Khadduri, Ph.D. – Abt Associates;
  • Marianne Nazzaro – HUD’s Office of Public and Indian Housing; and
  • Todd Richardson – HUD’s Office of Policy Development and Research.

HUD has also published an anticipated timeline for the expansion.

Early Summer 2016

Publish a summary of submitted comments on www.hud.gov/mtw.

Summer 2016

Begin the calls with the advisory committee, with an in-person meeting in Washington, DC in late-summer.

Fall 2016

Publish the notice to select the initial cohort of MTW agencies, with up to four months to submit applications.

Spring/Summer 2017

Select initial cohort of new MTW public housing authorities.

 Additional Resources:

Read the full HUD Press Release here.

Read NAHRO’s coverage of the FY 2016 appropriations bill and the included MTW expansion here.

NAHRO Submits Comments on HUD’s UPCS-V Demonstration

~ Tushar Gurjal

On Friday, June 17, NAHRO submitted to HUD its comment letter on HUD’s UPCS-V Demonstration. NAHRO encourages all interested parties to provide their comments to HUD and comments may be submitted until July 5, 2016. NAHRO’s comments are split into four primary sections. They discuss concerns about the costs of transitioning to the UPCS-V protocol; concerns about the UPCS-V Demonstration; concerns about the protocol itself; and feedback on specific inquiries about the protocol. NAHRO hopes that HUD will carefully consider these comments as it moves forward with the UPCS-V Demonstration.

Members can read NAHRO’s full comments here.