Voucher Program Contingencies

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



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)



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