NAHRO Policy Team Blog

  • Jonathan Zimmerman March 15, 2013 04:48pm EDT

    Voucher Program Contingencies:

    Knowing About All Possible HAP and Administrative Cost Savings Options Available, How To Plan and Implement Them

    Friday, March 22, 2013

    Part II: 3:30 – 5:00 pm (EDT)

    This session will cover existing measures PHAs can consider implementing within their discretionary authority under existing regulations, PIH Notices (listed below in related resources), and other measures PHAs have employed to help contain or reduce their Housing Assistance Payment (HAP) and voucher program administrative expenses.   Panelists will also cover HUD’s existing waiver request and approval process.  Panelists will cover “significant” amendments to PHA Plans, meetings with Boards of Commissioners and the community, and changes to PHAs’ administrative plans.’

    With the level of HAP and administrative fee cuts under the sequester, and possible funding reductions in the future, beyond PHAs’ education and advocacy with their elected officials about the impacts of these funding levels, PHAs are hard pressed to figure out how to realize costs savings and reductions into practice.   This is a very difficult task to accomplish at small, medium or large PHAs operating in a rural, suburban or urban housing market, without compromising the core integrity of your voucher programs.  This session will cover a range of ways some PHAs have had to put into place budget and programmatic contingency plans to their voucher program operations in the last several months, weeks and days, in order to deal with current and possible future funding reductions.

    There are processes some PHAs have had in place to administer their voucher programs for quite some time that served them well when funding was adequate, while other PHAs have modified how they administer their voucher programs over the last several years out of financial necessity.  In all circumstances, panelists will assist PHAs accomplish HAP and administrative expense savings where possible, while trying to preserve as best as possible  their core program performance that is important to their Boards of Commissioners and the communities they serve.  

    This part of the webinar will also feature an extensive question and answer period. 

    Moderator / Panelist

    Mr. Jonathan Zimmerman

    Senior Policy Advisor

    NAHRO (DC)

    Panelists

    Bryan Hoffman

    Executive Director

    Lebanon County Housing Authority

     

    Mr. Rob Fredericks

    Deputy Executive Director

    Housing Authority of the City of Santa Barbara (CA)

     

    Bob Peirson

    Finance Director

    Housing Authority of the City of Santa Barbara (CA)

     

    Veronica Loza

    Director of Housing Management

    Housing Authority of the City of Santa Barbara (CA)

     

    Ms. Lori Rosendahl

    Chief Operating Officer

    Grand Junction Housing Authority (CO)

     

    Ms. Debbie Armenta

    Grand Junction Housing Authority (CO)

     

    Ms. Racquel Wertz

    Grand Junction Housing Authority (CO)

     

    Mr. Levon Lamy

    Staff Accountant

    PH Enterprizes (AZ)

    phenterprizes.com

     

    Other PHAs (to be announced)

    Related Resources – Part II

    To maximize our members and panelists’ time during parts I & II of NAHRO’s March 22, 2013 webinars, we strongly encourage our members to make use of these related resources prior to the webinar.  After registering for this webinar, these and other materials will be loaded into a web browser for use and discussion with the panelists.

    • PIH Notice 2013-4: Prior to HUD’s issuance of PIH Notice 2013-4, PHAs were required to verify the documentation submitted by households of various sources of income and/or benefits, despite the fact that some or all of these amounts are excluded for purposes of determining eligibility and rent calculations.  HUD issued PIH Notice 2013-4, to reduce administrative burdens on PHAs.  A full copy of the notice is accessible at:  http://www.nahro.org/sites/default/files/searchable/PIHNotice2013-4.pdf

     

     

     

    • PIH Notice 2012-26:  Under PIH Notice 2010-19 titled, “Administrative Guidance for Effective and Mandated Use of the Enterprise Income Verification (EIV) System” as extended under PIH Notice 2012-26 through the present, several improvements and a streamlined income verification method were made available to PHAs (as well as their affiliates or instrumentalities) to implement in the Public Housing, Section 8 Tenant-Based Voucher, Section 8 Project-Based Voucher, and Project-Based Certificate programs.   This notice might have been overlooked by some because its subject title of PIH Notice 2010-19 was not descriptive of the actual changes that HUD authorized in the Income Verification Hierarchy.  A full copy of PIH Notice 2012-26 and NAHRO’s article on the Notice and regarding households with seasonal or cyclic income [24 CFR 5.609(d)] are accessible at:  http://www.nahro.org/phas-revisit-pih-notice-2010-19-2011-25-and-2012-26-order-reap-all-relief-benefits-possible

     

    • PIH Notice 2012-15:  The cost-saving measures described in HUD’s notice are optional and have varying degrees of impact on each PHA.   Depending on the measure in question, sometimes there is an interplay between changes in discretionary administrative practices that has an impact on a PHA’s Housing Assistance Payment (HAP) expenses and other times making a change would have an impact on how they can serve their community.  As such, each PHA should consider the impact of each action prior to implementation. A full copy of HUD’s notice is at:  http://www.nahro.org/sites/default/files/searchable/pih2012-15.pdf.

     

    • PIH Notice 2011-29:  On June 3, 2011 HUD issued a notice (PIH Notice 2011-29) to among other things, renew PIH Notice 2010-10 regarding HUD’s program requirements that apply to Housing Quality Standards (HQS) and supplementary guidance that PHAs and inspectors may rely upon when conducting inspections.   If the PHA determined from the inspection that the unit did not meet the HQS requirements, the PHA may allow the unit to pass upon verification that the HQS deficiency has been corrected. The regulation at 982.404(a)(3) states that the PHA "verifies" HQS repairs. The PHA may elect to do a reinspection to comply with 982.404(a)(3) to verify that all HQS deficiencies have been corrected. However, a reinspection is not necessary if the PHA can obtain verification through other means. For example, a PHA might accept an owner's certification that required repairs were completed and then verify that action at the next on-site inspection. Further, a PHA might tie the verification process to the severity of corrections needed and/or its experience with the owner and property. PHAs should include in the PHA‟s Administrative Plan how the PHA will verify the correction of HQS deficiencies.  A full copy of the notice is accessible at:  http://www.nahro.org/sites/default/files/searchable/PIHNotice2011dash29.pdf

     

    • PIH Notice 2011-28:  HUD has also issued PIH Notice 2011-28 to extend and revise PIH Notice 2009-44 which provided: (1) guidance on cost-saving measures PHA may take to address financial shortfalls by reducing costs in the HCV program; and (2) information on the circumstances under which a PHA may deny a move under 24 CFR § 982.314(e)(1) or terminate a housing assistance payments (HAP) contract under 24 CFR §982.454 as a result of insufficient funding. A full copy of the notice is available at http://portal.hud.gov/hudportal/documents/huddoc?id=pih2011-28.pdf

     

     

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  • Jonathan Zimmerman March 15, 2013 04:36pm EDT

    The Sequester and Pending Enactment of FY 2013 Appropriations:

    How to Estimate Voucher Program Eligibility, Funding, and Model Program Contingencies

    Friday, March 22, 2013

    Part I:  noon – 3:00 pm (EDT) 

    All PHAs administering Section 8 vouchers, can access valuable program data to help them better understand their HAP and administrative fee expenses as well as the attendant underlying causes for their expenses.  This session will provide an illustrated step-by-step explanation of how to access important PIC data through HUD’s Adhoc Report, coupled with examples of how PIC data can be used to help PHAs model budget contingencies and cost reduction measures in 2013 and beyond.  PHA and HUD panelists will help make this something that all PHAs can implement.  This session is for PHAs that have a customized software system or utilize their own spreadsheets, use HUD’s HCV Two-Year Forecasting Tool (v. 8.8), and/or have no customized software program.  All of the mathematical examples to be presented are the same as would be generated by using the HUD’s spreadsheet.

    The margin of error in making accurate assumptions about per voucher HAP costs, turnover rates, lowering voucher payment standards or any other cost reduction measures is razor thin in 2013 and possibly into the future.  What used to be a sufficient level of analysis in the past may not be precise enough in 2013 and beyond.  If some PHAs think they already know the answers to all of the issues they are facing, think again.  Do you know what the average voucher HAP costs are for per voucher-assisted households leaving the program through turnover vs. your PHA’s average per voucher HAP costs?  Do you know your PHA’s actual projected average voucher HAP costs for 2013 vs. the amount of HUD’s inflated per voucher HAP costs for your PHA and the implications?  If you model the impacts of possible voucher payment standard reductions, with or without a waiver approval from HUD, do your projections account for the wide range of related programmatic impacts and are they accurate?  It is critically important that PHAs have a high degree of reliability in their estimates and cost saving measures well before they get towards the end of a calendar year, when the adverse consequences of insufficiently accurate estimates, assumptions and cost modeling become increasingly dire.

    Listed below is an outline of the topics that will be covered in first half of this session:

    1.      Basics 101 – Background

    2.      Data 101 - Extracting Information From PIC

    3.      Data 201 - Analyzing Data

    4.      Data 301 - Managing Data

    5.      Forecasting - 101 Estimating Funding Levels

    6.      Forecasting - 201 Is There Enough Money?

    7.      Forecasting - 301 Sequestration

    8.      Forecasting - 401 Beyond Sequestration

    9.      Questions and Answers

    Listed below is a summary of the topics that will be covered in second half of this session.

    To assist PHAs maximize their Housing Assistance Payment and Net Restricted Asset funding to serve the greatest number of families possible each calendar year, HUD developed and issued an updated version of its HCV two year forecasting spreadsheet (v. 8.8) to PHAs.  HUD will go through the basics and finer points of how to utilize the spreadsheet.  This part of the webinar will also feature an extensive question and answer period.  By learning the basics and fine points of how to utilize all of the features of HUD’s HCV Two-Year Forecasting Tool (v. 8.8), benefits include:

    ·         Pinpointing the optimum number of vouchers to issue to maximize leasing without over-spending available HAP funding or over-leasing the  baseline number of vouchers in a calendar year;

    ·         More accurate predictions of the share of voucher holders that will lease up, so PHA staff can issue the appropriate number of vouchers (if applicable) to maintain high utilization rates and earn maximum administrative fee revenues;

    ·         Reducing the number of households that need to go through the intake, eligibility determination, briefing and HQS inspection processes by maximizing all types of success rates thereby reducing PHAs’ administrative fee expenses;

    ·         Minimizing much of the unpredictability associated with voucher leasing and budget utilization’s never ending “roller coaster ride” of increased and decreasing leasing and transition towards greater stability of their voucher operations over a two year period; 

    ·         Determining how to best deploy limited staff resources to the admissions, occupancy and initial leasing side of their operations and the “payback” resulting from such moves over several months and throughout the years to come;

    ·         Modeling different scenarios on voucher issuance and payment standards to help each PHA assess their calendar year-to-date lease-up and budget utilization rates; and

    ·         Evaluating leasing and cost estimates versus actual program performance so that agencies can make necessary adjustments throughout the calendar year.

    Moderator

    Mr. Jonathan Zimmerman

    Senior Policy Advisor

    NAHRO

    Panelists

    Mr. Bryan Hoffman

    Executive Director

    Lebanon County Housing Authority (PA)

     

    Mr. Michael LaRiccia

    Program Advisor

    HUD PIH Office of Field Operations

    Related Resources – Part I

    To maximize our members and panelists’ time during parts I & II of NAHRO’s March 22, 2013 webinars, we strongly encourage our members to make use of these related resources prior to the webinar.  After registering for this webinar, these and other materials will be loaded into a web browser for use and discussion with the panelists.

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  • Jonathan Zimmerman September 06, 2012 04:45pm EDT

    On August 15, 2012, the General Accountability Office (GAO) issued a report regarding HUD’s FY 2012 notice of funding availability (NOFA) rebid for the administration of Project-Based Contract Administrator (PBCA) cooperative agreements, that sustained the protests of several agencies around the country.

    A copy of GAO's report is available here.

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  • Jonathan Zimmerman August 10, 2012 11:15am EDT

    Summary:  HUD’s Office of Inspector General’s (OIG) audited the Department’s controls over the Section Eight Management Assessment Program (SEMAP).   HUD IG’s report titled, “The Section Eight Management Assessment Program Lacked Adequate Controls To Accomplish Its Objective” (Audit Report No. 2012-AT-0001) concluded that HUD had not developed adequate controls to ensure that SEMAP would be effective in identifying underperforming PHAs administering Section 8 voucher programs.  Other conclusions in the audit report are that HUD’s Field Offices visited during the review, performed SEMAP requirements inconsistently.  In response, HUD recognized weaknesses in the program and stated their plans to improve SEMAP’s controls, including implementation the Next Generation Management System (NGMS) and a new Portfolio Management Tool.

    HUD IG’s office recommended HUD develop and implement improved controls over SEMAP as it currently exists, including reducing HUD’s reliance on self-certified agency data and annual audit reports.  They also recommend that HUD improve its controls over how field offices perform program requirements.

    Publication Issuance Date:  August 3, 2012

    View the report here.

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  • Jonathan Zimmerman August 10, 2012 11:11am EDT

    Summary:  HUD issued proposed Fair Market Rents (FMRs).  The proposed FY 2013 FMRs in HUD’s notice reflect several updates to the methodology used to calculate FMRs.  First, HUD has updated the bedroom ratios used to calculate 0, 1, 3 and 4 bedroom FMRs based on the 2 bedroom

    FMR. The new bedroom ratios are constructed using 2006–2010 5-year American Community Survey (ACS) data. The methodology for calculating the bedroom ratios is very similar to the method used when the bedroom ratios were based on 2000

    decennial census long-form data.  Second, these FMRs reflect a new trend  factor calculation methodology which HUD stated would be implemented in its proposed FY 2012 FMR publication on August 19, 2011 (76 FR 52058). This trend factor is based on national gross rent data and will change annually. Comments are due on September 4, 2012.  NAHRO will be filing comments through www.regulations.gov.  NAHRO members are encouraged to share their comments with us for this purpose at jzimmerman@nahro.org

    Publication Issuance Date:  August 3, 2012

    View the notice here.

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  • Jonathan Zimmerman February 21, 2012 08:44am EST

    In the mid-afternoon on Friday, February 17, 2012 HUD sent PHAs that administer Section 8 voucher programs, an e-mail with their 12/31/2011 Net Restricted Asset (NRA) balance reports for their final review.  If a PHA finds that the HUD calculated NRA balance differs from HUD’s calculated balance as of December 31, 2011 by more than an immaterial amount (e.g., 3%), they must contact their assigned Financial Analyst at the FMC within two business days of receiving HUD’s letter on February 17, 2012 to discuss it and resolve any problems. HUD set Thursday, February 23, 2012 as date for the PHAs to resolve any major differences with their FMC Financial Analysts. If HUD does not have the correct NRA balance for a PHA by Thursday, February 23, 2012, NRA funds could be offset from them in their final 2012 Housing Assistance Payment (HAP) budget authority that should not be subject to the offset. 

    As previously reported, the “Consolidated and Further Continuing Appropriations Act of 2012” (P.L. 112-55) included a $650 million rescission/offset from PHAs’ Net Restricted Assets, as determined by HUD.  The Act enables HUD to derive the required $650 million rescission from reductions to PHAs’ calendar year 2012 allocations.  The Department acknowledged that the truncated time frame for final resolution of their NRA balances as of 12/31/11 is very short, however, they state having to meet the Congressional mandate to announce the renewal funding awards by 3/1/2012, which leaves them with less than seven business days to complete this process.  

    HUD reports that some PHAs with significant variances between their reported NRA balance and HUD calculations at 9/30/2011, provided to PHAs by HUD in their mid-December 2011 notices and spreadsheet enclosures, unfortunately did not take the opportunity to review it with HUD at that time.   PHAs showing significant differences between their VMS-reported NRA vs. the HUD calculated NRA, and VMS-reported Cash and Investment balances – all as of December 31, 2011, will also get a direct e-mail from a designated HUD staff member recommending resolution of these differences immediately.  HUD is urging these PHAs to take this final opportunity before the offsets are determined. 

    HUD’s letter states, “PHAs are expected to have sufficient resources in cash and investments to support the full NRA value, and it is critical that the calculated NRA is accurate. Any concerns regarding the December 2011 roll-forward balance need to be raised immediately. In addition, if your PHA does not have the cash and investments to support your December 2011 NRA balance, you must immediately notify your FMC financial analyst of that situation and report the cash and investments your agency does have to support the NRA balance. Note that voucher program cash and investments are considered available to support the NRA before supporting the Unrestricted Net Assets.”

    Over the last two weeks, HUD has considered over 800 changes from PHAs that contacted their FMC Financial Analysts during the 9/30/2011 NRA balances review period (in mid-December 2011).  HUD states that previously agreed upon changes to the 9/30/2011 balances are already incorporated in the 12/31/2011 balances PHAs just received. 

    If a PHA’s self-reported NRA value varies significantly from HUD’s calculated roll forward balance, the PHA is encouraged to review its reported revenues and expenses as a potential basis of the discrepancy and to follow the same steps outlined in HUD’s letter and/or spreadsheet with definitions and HUD’s methodology to calculate the roll forward balance.

    When contacting your financial analyst, PHAs must identify the values in the calculation that are causing the discrepancy and they must be able to provide documentation that supports their proposed revisions.  Any changes PHAs provide to VMS data in this process will apply only to the calculation of their NRA balance.  HUD will not revise PHAs’ CY 2012 HAP funding allocations as a result of any changes in VMS figures as part of this process.

    PHAs with questions are instructed by HUD to call their respective Financial Analysts (or contact designated in the direct email if other than their FA) immediately.  HUD’s due date will not be extended and HUD states that PHAs will be held accountable for differences that were not resolved within the opportunities provided during 9/30 and 12/31/2011 NRA review periods.

    Here is an example of HUD’s letter, spreadsheet enclosure with financial figures, and spreadsheet enclosure with definitions and an explanation of the Department’s calculations and methodology.

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  • Emily Pasi February 12, 2012 10:18pm EST

    Last Tuesday, February 7, the Insurance Housing and Community Opportunity Subcommittee of the House Financial Services Committee marked up a discussion draft of the Affordable Housing and Self Sufficiency Improvement Act of 2012 (AHSSIA). Formerly known as SESA, a major change in this piece of legislation will be the increase in MTW authority among PHAs. NAHRO has provided a detailed summary of the hearing here. A webcast of the mark-up is also available for viewing at http://mfile3.akamai.com/65722/wmv/sos1467-1.streamos.download.akamai.com/65726/markup020712.asx.
     .

    The Obama Administration released its Housing Scorecard for the month of January on Monday, February 6. The Administration’s report offered mixed signals on the health of the housing market.

    Lastly, NAHRO is seeking member input on new regulations regarding the HOME Investment Partnerships Program. HUD is revamping the program with the goal of improving overall performance. The deadline to submit comments to HUD is Tuesday, February 14.  Your feedback will assist us in the development of NAHRO’s formal comment letter. Please send your feedback via email to Jeff Falcusan, Director of Policy and Program Development, at jfalcusan@nahro.org.

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  • Jonathan Zimmerman February 08, 2012 01:13pm EST

    With drastic reductions in ongoing administrative fees, PHAs are challenged with both meeting voucher program requirements and budgeting operations.   Even PHAs with best practices are working through the challenges of operating voucher programs successfully in this funding environment.  On behalf of one of our PHA agency members, NAHRO sent a list of questions to our members signed up to NAHRO’s NetworkCentral – Section 8 http://www.nahro.org/email-list

    1.       How many total vouchers does your agency administer, how many square miles is within your agency’s service area, and what is the total population within your service area? 

    2.       What is your case load per Housing Specialist / Caseworker?   Is it too high and what would you consider optimum?  

    3.       Do your FSS coordinators complete program activity (certifications and recertifications? 

    4.       Are you doing interims re-exams for increases in household income? 

    5.       Do you have Housing Specialist / Caseworker complete recertifications in the units for elderly or disabled households, and HQS Inspections? 

    NAHRO catalogued agency members’ answers to the five questions posed, and grouped them in ascending order by PHAs’ voucher program size.  A copy of PHAs’ responses to these questions is available at: 

    We would like to thank all of the PHAs that replied to this list of questions.

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  • Emily Pasi February 01, 2012 11:37am EST

    The latest edition of the NAHRO Monitor is now available online. Be sure to check out HUD Publishes Guidance on Eligible Uses of Operating Fund and Voucher Program Information to Help PHAs Begin CY 2012.

    On Monday, January 30, HUD Secretary Shaun Donovan announced new regulations intended to ensure open public housing to all eligible persons, regardless of sexual orientation or gender identity. Supported by the Obama Administration and U.S. Congressman Barney Frank (D-Mass), the final rule will go into effect 30 days after the rule is published.

    In a study released on Monday by the Manhattan Institute for Policy Research, researchers found that cities are more racially integrated than any time since 1910. Click here to read the full report.

    The number of public housing authorities banning smoking in units continues to be a growing trend. The Housing Authority of the City of Freeport (HACF) announced today that as of June 1 all units will be smoke free.

     

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  • Jonathan Zimmerman January 24, 2012 01:52pm EST
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