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AudioShort Tapes and Materials
Playing It Smart With Proposed FY 2005 FMRs
Due to rebenchmarking from the 2000 Census, and the changes in area definitions
used to determine the FY 2005 proposed Fair Market Rents (FMRs), FMRs are substantially
less and sometimes substantially greater than agencies’ FY 2004 FMRs. In
both cases, agencies are grappling with the FMR appeals process, as well as setting
new payment standards, all during a time when PIH Notice 2004-7 caps Housing Assistance
Payments times the AAFs. In short, the proposed FMRs raise numerous competing
issues that could ruin an agencies’ lease-up rate or create further financial
shortfalls in the future. Fortunately, it's not too late for agencies to file
appeals and mitigate ensuing problems. In addition to the comment deadline of
September 7, 2004, HUD will allow an additional 60-days (i.e. November 8, 2004)
to appeal the proposed FMRs), of both local rents and the new area definitions.
These AudioShorts will provide agencies with information to:
- Analyze the current payment standards in relation to their FY 2004 FMRs
versus the dollar amount after revising their payment standard in relation
to the proposed FY 2005 FMRs;
- Understand the repercussions of proposed FY 2005 FMRs on agencies’
renewal funding versus actual HAP costs under HUD’s FY 2004 budget-based
renewal formula (PIH Notice 2004-7) as well as the potential impact on their
lease-up rates, households’ initial rent burdens (i.e. 40 percent cap),
agencies’ “affordability standards,” and deconcentration efforts;
- Appeal the proposed FMRs on both local rents using Random Digit Dialing
surveys or alternate rent studies with acceptable scope and methodologies;
- Appeal the proposed FMRs on adequacy of adding or removing counties to form
the new area definitions (i.e. Core-Based Statistical Areas [CBSAs], Micropolitan
Area); and
- Analyze the optimal payment standards for both FY 2004 and FY 2005, within
agencies’ “basic range,” or applying for “exception payment
standards” or “special exception payment standards,” as well
as by bedroom size, neighborhood and agency service area.
Why Should I Appeal the Proposed FY 2005 FMRs?
At a time when HUD’s FY 2004 Section 8 renewal policy has forced agencies
to reduce Housing Assistance Payments (HAP) in order to offset funding shortfalls
this year, many agencies may be wondering why it is worth appealing the proposed
FY 2005 FMRs even if they are inadequate. If after review and analysis of the
proposed FY 2005 FMRs, housing agencies find them below comparable private market
housing costs, they should not be reluctant to file an appeal.
The FY 2005 FMRs will apply in 2005. The final FY 2005 VA, HUD and IA Appropriations
bill – which applies to funds from January – December 2005 – may
restore a renewal formula based on actual HAP costs that has served the HCV program
well. If this occurs, than agencies that file successful FMR appeals will have
an adequate FMR from which they can still establish suitable payment standards
above or below that amount, as well as performing the required rent reasonable
process.
Panelists for the September 1 AudioShort
- Greg Mahnke, Executive Vice President, ORC Macro, Burlington, VT
- Meryl Finkel, Senior Associate, Abt Associates Inc., Cambridge, MA
- MaryAnn Russ, Principal Associate, Abt Associates Inc., Sarasota,
FL
- Jonathan Zimmerman, Housing Policy Analyst, NAHRO, Washington, DC
Panelists for the September 9 AudioShort
- Danna Moore, Ph.D., Assistant Director, Social & Economic Sciences
Research Center, Washington State University, Pullman, WA
- Meryl Finkel, Senior Associate, Abt Associates Inc., Cambridge, MA
- Victoria Main, Senior Associate, Abt Associates Inc., Sarasota, FL
- Jonathan Zimmerman, Housing Policy Analyst, NAHRO, Washington, DC
AudioShort Tape Order Form -- Please specify which
CD you would like, the September 1 or the September 9th. |
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