NAHRO Provides PHAs with Initial Estimates of 2012 Admin. Fee Rates at 100 Percent Eligibility

In mid-January 2012, HUD notified PHAs of the Department’s estimated ongoing administrative fee pro-ration at 75 percent for the calendar year, which will be applied to all PHAs equally.  However, because 2012 ongoing administrative fee rates have not been published yet, PHAs are hard pressed to estimate their annual ongoing fee revenues as well as corresponding cuts.   NAHRO is providing members with initial estimates of each PHA’s 2012 ongoing administrative fee rates, which are not intended to replace HUD's official pending FY 2012 fee rate publication, but rather to assist PHAs in estimating possible fee cuts and annual revenues in the interim. 

NAHRO’s PHA-by-PHA estimates of ongoing fee pro-rations are available here.  The method NAHRO used to estimate PHAs’ 2012 ongoing fee rates involved taking the annual inflation factor of each PHA’s 2011 ongoing fee rate compared with its 2010 rate (columns A and B), then applying the identical rate to each agency’s column A and column B fee rates for 2011.  Ongoing administrative fees apply to the Housing Choice Voucher Program and other voucher programs such as HUD-VASH, FUP, Mainstream/Non-Elderly Disabled voucher programs. These fees also apply to the Moderate Rehabilitation program and the 5-Year Mainstream program.  PHAs may choose to use these fee rates to determine billing amounts for portability activities. To avoid the need to repeatedly change billing amounts due to pro-rations, PHAs may use the 75 percent of Column B fee rate from January to calculate portability fees for every month in the year.

HUD expects to notify PHAs of their final 2012 Housing Assistance Payment allocations and Net Restricted Asset offsets (if applicable) by mid-February 2012.  In the past, HUD has provided PHAs with their ongoing administrative fee rates and corresponding funding distributions after distributing PHAs’ final HAP budget authority notices.  Waiting to make decisions about the operation of their voucher programs during the limbo period between January 1^st and when PHAs receive their ongoing administrative fee funding amounts (which are always retroactive to January 1^st) before putting their voucher program operations into full gear, has hurt PHAs’ programs in the past. 

HUD provided PHAs with disbursements of ongoing administrative fees for January through March 2012.  The administrative fees provided for January through March 2012 are an estimated amount based on the leasing data reported in the Voucher Management System (VMS) for September 2011. The amount was capped to the number of unit months available (UMA); prorated to 75 percent of eligibility; and calculated using the 2011 ongoing administrative fee rates.

Going forward, the Department will continue to use the Voucher Management System (VMS) to calculate administrative fees based on first of the month leasing, and to reconcile the estimated fees advanced with the actual earnings for each month based on the actual Unit Months Leased for that given month.  The lag period between PHAs’ monthly reported leasing and HUD’s validation of agencies’ actual leasing compared with the Department’s initial disbursement of administrative fees averages approximately four months later.

Two fee rates are provided for each PHA. The first rate, Column A, applies to the first 7,200 unit months leased in CY 2012 (or first 600 vouchers leased per month). The second rate, Column B, applies to all remaining unit months leased in CY 2012 (601 vouchers leased or more per month).  The fee rates for each PHA are those rates covering the areas in which each PHA has the greatest proportion of its participants, based on PIC data.  In some cases, PHAs have participants in more than one fee area.  If a PHA so chooses, the agency may request that the Department establish a blended fee rate schedule that will consider proportionately all areas in which participants are located.  The higher of the calculated blended rates or the HUD determined 2012 administrative fee rates for the PHA will be used for the PHA's CY 2012 on-going administrative fees.  Once a blended rate schedule is calculated, it will be used to determine the PHA's fee eligibility for all quarters of CY 2012.  A PHA that received a blended fee rate schedule for 2011 will not receive it automatically for 2012; it must be requested.  Guidance to request blended fee rates during 2012 will be provided in HUD’s 2012 HCV Funding Implementation Notice.

PHAs interested in estimating their 2012 HAP budget authority and NRA offsets may refer to “NAHRO Provides PHAs with Tools to Estimate 2012 Voucher Funding Now” and “new article”“NAHRO Provides Supplementary Instructions to Help PHAs’ 2012 NRA Offsets.”

Please direct questions to Jonathan Zimmerman, NAHRO’s Senior Policy Advisor for Housing Assistance Programs, at  jzimmerman@nahro.org.