NAHRO's Requests for Congress and HUD
The National Association of Housing and Redevelopment Officials (NAHRO) is asking for $31.7 billion in additional funding and regulatory relief to help public housing agencies (PHAs) and housing providers protect their residents’ homes, health and safety during the COVID-19 pandemic.
NAHRO's Requests to Congress for Additional HUD Resources to Address COVID-19
Due to economic uncertainties, residents of public housing and participants in the Section 8 programs may face due to the coronavirus pandemic, Congress should provide additional funding to ensure agencies can continue to provide critical and necessary housing and services to their residents. This represents additional funding (six months’ worth) that PHAs and private housing providers will use due to lost rental revenue from tenants and costs associated with evolving social distancing and quarantines guidance from local, state and federal governments. This also includes a significant investment in Community Development Block Grant formula funding to provide communities with additional flexible resources to address the pandemic. This funding will also assist PHAs and housing providers in providing increased sanitation at public housing and multifamily sites, in addition to direct services for residents. This will also ensure PHAs have enough funding to take precautionary measures that will protect both PHA staff and residents, including systems for virtual briefings, public meetings, eligibility interviews, and interim income reviews.
- $10 billion for Housing Assistance Payments (HAP) account
- $1 billion for Admin Fee account
- $2.5 billion for Operating Fund account
- $1.5 billion for Capital Fund Account
- $6.7 billion for PBRA
- $10 billion for CDBG
Flexibilities Will Ensure PHAs Can Continue Operating Effectively
Congress should also provide additional flexibility to PHAs so that they can use federal funds to address urgent concerns. Congress should provide PHAs with full fungibility of their existing funding between the HAP, Admin Fee, Operating Fund, and Capital Fund accounts during the next six months, so PHAs can serve the maximum number of local residents.
Suspension of the CSSR Critical for Social Distancing
As residents of public housing should also be heeding federal and local social distancing guidance, Congress should suspend the Community Service and Self-Sufficiency Requirement (CSSR).
NAHRO's Requests for HUD
In addition, NAHRO sent a letter to HUD with 16 requests. The full letter is available in PDF here, and the text is below.
Dear Assistant Secretary Kurtz:
On behalf of the National Association of Housing and Redevelopment Officials (NAHRO), I would like to offer the following comments to the United States Department of Housing and Urban Development (HUD or the Department) regarding the current spread of COVID-19 and its effects on Public Housing Agencies (PHAs), program participants, and residents.
Formed in 1933, NAHRO represents over 20,000 housing and community development individuals and agencies. Collectively, our members manage over 970,000 public housing units, 1.7 million Housing Choice Vouchers (HCVs), and receive over $1.5 billion in Community Development Block Grant (CDBG) and HOME Investment Partnerships (HOME) Program funding to use in their communities. NAHRO has the unique ability to represent public housing agencies, local redevelopment agencies, and other HUD grantees of all sizes and geography.
The spread of COVID-19 has caused a fundamental shift in operating circumstances throughout the country. The health and safety of our residents and program participants is the paramount concern for housing agencies and community redevelopment groups around the country. Our members are all taking steps to ensure that all agencies are able to carry out their vital missions while still ensuring a healthy and safe environment for employees, program participants, and residents.
While NAHRO appreciates the initial guidance that the Department has published in the form of a Frequently-Asked-Questions document and an email address which to direct questions, we believe that HUD should be doing more to assist PHAs during this time. With that in mind, after consultation with our members, we offer the following suggestions to HUD. To the extent that any of these suggestions may require statutory changes, please let NAHRO know by contacting Georgi Banna at email@example.com with the appropriate statutory citation.
1. An Administration request for additional funding from Congress on behalf of the Department – while NAHRO is also independently seeking additional funds, the Administration should ask Congress for additional funding to ensure that PHAs can take all steps necessary to prevent the spread of COVID-19 and protect the health and safety of their residents and staff.
2. Suspension or postponement of all inspections (including Housing Quality Standards and NSPIRE inspections) – at this time, most Public Health Departments, as well as the Centers for Disease Control, are advocating for social distancing. Inspections have the potential to spread the virus to residents and place inspectors in jeopardy as they may have to interact with many people in carrying out their inspections. Additionally, moving to biennial inspections is not a solution for those who already have it in place, but nonetheless have an inspection coming up. This should apply to initial and annual inspections. 2
3. Provide guidance allowing landlords or landlords and tenants to self-certify HQS acceptability – this will allow HUD to reduce the COVID-19 exposure to landlords and tenants. It would not require a statutory change, if the above is not available immediately.
4. Temporary postponement of re-examinations – as mentioned above, the face to face contact between PHA employees and residents has the potential to further the spread of the virus, posing a danger to both PHA staff and residents. If HUD chooses to postpone these reexaminations, then it should do so at least until there is firm guidance on how to institute reexaminations in a virtual setting and give a reasonable amount of time for PHAs to institute these virtual re-examinations. Additional time may have to be given to PHAs that are not immediately able to set up these virtual re-examinations.
5. Suspension of re-examination documentation requirements – at this time, residents may have a hard time finding appropriate documentation for their loss of income. Residents should be able to self-certify their lost income, so that PHAs can appropriately readjust their rents. Alternatively, HUD may want to consider allowing PHAs to use participants’ actual past income in verifying income as was done in the notice PIH 2013-03 (HA) titled “Public Housing and Housing Choice Voucher Programs – Temporary Compliance Assistance.”
6. Suspension or postponement of the Section 8 Management Assessment Program (SEMAP) and the Public Housing Assessment System (PHAS) – until we have a better idea of how this event will affect utilization, it does not make sense to continue to use this assessment metric. While these assessment tools provide valuable information on PHA performance during normal times, the current situation demands a more thoughtful approach.
7. Guidance and best practices documents on moving PHA activities to virtual environments – as the current situation has the potential to last several months, NAHRO understands that regular program activities will have to be re-thought. The Department should provide information on how best to conduct these activities.
8. Weekly (or more frequent) stakeholder calls – the Department should be holding calls at least weekly to keep PHAs and other stakeholders aware of the current situation, what it is doing, and to receive feedback directly from on-the-ground individuals who are best positioned to know the needs from a variety of places around the country. Transparency and sharing information easily is crucial right now.
9. Post dates on guidance published on HUD’s COVID-19 page – while we greatly appreciate HUD creating a COVID-19 page with the latest guidance, given the evolving nature of the event, we believe that HUD should post dates by the links to the guidance on the website. This will allow HUD stakeholders to make sure that they are accessing the most recent guidance. Having stakeholders navigate between many documents to find the most recent guidance is confusing and may send mixed messages.
10. Extend deadlines for grant applications, regulatory comments, and other regular information collections or submittals – the unprecedented nature of this event has caused time that may have been used to complete these activities to be diverted to other activities. The Department should take this into account.
11. Postpone Quality Assurance Division (QAD) reviews - the Department should also postpone QAD remote reviews that may be scheduled (e.g., Voucher Management System or Rent Reasonableness reviews).
12. Other HUD reviews should be postponed – other reviews from other subagencies within HUD should temporarily be postponed until PHAs are operating under a plan in place which ensures critical functions remain in place.
13. Postponement of obligation and expenditure deadlines – the COVID-19 event will make it difficult to meet some of these expenditure deadlines. They should be postponed.
14. Suspension or postponement of alteration requirements of the annual plan – while HUD has indicated a willingness to suspend annual plan public meeting requirements on a case-to-case 3 basis, at this time, NAHRO believes that there should be a broader waiver for all PHAs. This will give PHAs the ability to quickly adapt to this constantly shifting emergency and allow PHAs to use the latest public health guidance (which is sometimes updated daily) in crafting their policies and procedures.
15. Renewal funding – this event has the possibility of dramatically altering utilization for the Housing Choice Voucher program. Renewal funding for the next fiscal year should not be based solely on voucher expenses as reported through the voucher management system in this year. Allowance must be made for the COVID-19 event.
16. Allowances for low utilization of special purpose vouchers – before the COVID-19 event, some of these special purpose vouchers (e.g., Mainstream vouchers) already had low utilization rates. In future allocations of these vouchers, some allowances must be made for the unique nature of this event. We thank and appreciate all the work that HUD is doing at this time.
We look forward at working collaboratively with HUD to ensure that residents and PHAs have an environment that appropriately protects their health and safety, while still ensuring that programmatic requirements are met.
Georgi Banna, Esq.
Director of Policy and Program Development