New HOME Notice on Allocating Eligible Costs and Identifying HOME-assisted Units in Projects

On August 25, HUD published  Notice CPD-16-15 which provides clarifying guidance to HOME participating jurisdictions (PJs) on the process of conducting a cost allocation using the Standard Method or the Proration Method, in accordance with HOME regulations. PJs are required to charge the actual costs of the HOME units, which will require allocating costs and identify the number and characteristics of units to be designated as HOME units for multi-unit rental or homebuyer HOME projects in which not all of the units are HOME-assisted (e.g., a mixed-income or a mixed-use project).

Among it’s topics, the Notice

  • explains the relationship of cost allocation to underwriting;
  • breaks down the cost allocation process, including what information is necessary and step-by-step explanation of the process;
  • highlights the requirements for special circumstances, such as owner-occupied projects with rental units, manager’s unit, and projects with HOME and public housing units;
  • provides additional guidance on disbursement of funds and documentation; and
  • includes process charts and examples for the Standard Method and the Proration Method.

HUD Publishes FY 2017 SAFMRs

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

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

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

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 Makes $33 Million Available for the Youth Homelessness Demonstration Program

Yesterday, HUD published the Youth Homelessness Demonstration Program (YHDP) Notice of Funding Availability (NOFA), opening up a competition to award $33 million to up to 10 communities (including 4 rural) across the nation. Awardees of the competition will use the federal resources to design and implement a coordinated community approach to ending youth homelessness.

YHDP applications must be submitted by a community’s  Continuum of Care (CoC) Collaborative Applicant and must be co-developed with a wide spectrum of community partners, including a youth advisory board (required), a state or local child welfare agency (required), youth homelessness housing and service providers, local school districts, workforce development organizations, law enforcement, judges, corrections and more.

YHDP applications are due by Wednesday, November 30, 2016. Additional information on the demonstration program can be found on HUD Exchange.

HUD-VASH Second Round Funding Announced

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

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

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.