NAHRO Submits Regulatory Reform Comments to HUD

On June 14, NAHRO submitted its comment letter to HUD’s request for comment on Reducing Regulatory Burden; Enforcing the Regulatory Reform Agenda Under Executive Order 13777.

NAHRO identified many regulations that would make good candidates for streamlining. Each of the regulations met at least one of the following reasons for streamlining:

(a) The regulation results “in the elimination of jobs, or inhibits job creation”;

(b) The regulation is “outdated, unnecessary, or ineffective”;

(c) The regulation imposes “costs that exceed benefits”; or

(d) The regulation creates a “serious inconsistency or otherwise interferes with regulatory reform initiatives and policies.”

The regulations listed are non-exhaustive. NAHRO’s comment letter is a start of a conversation between the Department and NAHRO. Given the limited time to compile this list, NAHRO expects to identify additional avenues for further regulatory streamlining, which we will share with the HUD.

NAHRO’s comment letter is organized into three sections: Public Housing and Section 8 recommendations; Community Planning and Development; and recommendations on cross-cutting programs and initiatives. Within each major section are topic headers with NAHRO’s recommendation on each topic.

HUD PIH Publishes Violence Against Women Reauthorization Act of 2013 Guidance

On May 19, HUD Office of Public and Indian Housing (PIH) published a new notice (PIH-2017-08) that provides guidance to PHAs and owners on the requirements of the “Violence Against Women Act of 2013: Implementation in HUD Housing Programs Final Rule,” (VAWA Final Rule, published November 16, 2016) with respect to the Public Housing and Housing Choice Voucher (HCV) programs (including the Project-Based Voucher (PBV)), and Section 8 Moderate Rehabilitation (Mode Rehab).

Overall, the VAWA Final Rule provides expanded housing protections for survivors of violence and fully codifies the provisions of the Violence Against Women Reauthorization Act of 2013 (VAWA 2013) into HUD’s regulations. At its core, VAWA 2013 prohibits housing providers from denying or terminating housing assistance on the basis that an applicant or tenant is a survivor of violence.

Notice PIH-2017-08 provides a summary of the major changes of the final rule’s impact on PIH programs and details who is eligible to receive VAWA protections and how eligibility is determined and certified.

Among its topics, the notice reviews policies for:

  • PHA Documentation Requirements
  • Notice of Occupancy Rights
  • Victim Confidentiality
  • Emergency Transfers (Emergency Transfer Plans must be in place by June 14, 2017)
  • Family Break-up
  • Record Keeping and Reporting Requirements
  • Developing Partnerships with Victim Service Providers
  • Lease Bifurcations
  • Establishing Waiting List Preferences
  • Landownership: Move with Continued Tenant-Based Assistance
  • Owners in the HCV Program
  • Assistance Under More Than One Covered Housing Program
  • Fair Housing and Nondiscrimination

Please note that this guidance does not encompass every aspect of the VAWA Final Rule and should be used in conjunction with the VAWA Final Rule. NAHRO will provide a deeper analysis of this PIH notice for members in a forthcoming edition of the NAHRO Monitor.

HUD Publishes Notice on the Modernization of the Housing Opportunities for Persons With AIDS Program

Last week, HUD published new guidance (notice CPD-16-17) for Housing Opportunities for Persons With AIDS (HOPWA) grantees explaining the changes to the HOPWA program  that resulted from the passing and signing of the Housing Opportunity Through Modernization Act (HOTMA) on July 29, 2016. The passage of HOTMA was a huge victory for NAHRO and its members because it provided housing authorities with the effective tools and mechanisms to improve the operation of their programs. The new law also provided long-awaited amendments to the HOPWA statue that modernizes the program’s allocation formula, and addresses administrative provisions and adds program definitions. HUD’s new notice describes how the HOTMA provisions will effect HOPWA formula allocations for FY 2017 and beyond. The notice also details the program changes that became effective on July 29, 2016 versus the program changes that must be implemented by HUD through future rulemaking.

Learn more about the modernization of the HOPWA program in next edition of the NAHRO Monitor – available November 15, 2016 (members only).