On June 12, HUD published Notice PIH 2015-10 (HA), “Project-Basing HUD-Veterans Affairs Supportive Housing Vouchers,” which revises and supersedes Notice PIH 2011-50. The new notice makes the following policy changes:
• In considering the challenges faced by HUD-VASH voucher holders in leasing up in the local rental market, as part of determining whether to approve a request to project-base, “HUD will no longer consider the most recent leasing indicator under SEMAP, since the leasing of HUD-VASH vouchers is dependent on referrals from the Veterans Affairs Medical Center (VAMC) or Community-Based Outpatient Clinic (CBOC), and the unit months and budget authority associated with these vouchers are not included in the SEMAP leasing indicator.”
• For newly constructed or rehabilitated units, housing authorities must submit a construction schedule. The notice indicates that though “there is no deadline for completion of newly constructed or rehabilitated units…more than 24 months between execution of the AHAP and PBV HAP contract would be considered an unreasonable amount of time and would require an explanation.” The notice also makes clear that housing authorities need not “shelve” HUD-VASH vouchers, so long as they can meet their contractual commitments.
• The project description requirements have been revised for greater specificity, including indication of housing authority ownership.
• The notice eliminates the requirement to document ability to provide tenant-based assistance if the family wants to move from its PBV unit after 12 months, “since HUD-VASH families do not have a preference for moving from their PBV units over non HUD-VASH families in PBV units.”
• The notice adds requirements to submit a copy of the RFP or evidence of a proposal for housing assistance awarded under a government program that required competitive selection and was selected within the past three years, copies of applicable sections of the PHA Plan and Administrative Plan related to the PBV proposed project, and a statement from the owner confirming that the project will serve the chronically homeless using the Housing First model.
• The notice requires housing authorities to submit, as part of any request to project-base HUD-VASH vouchers, an email from the local HUD Field Office Public Housing Director confirming that the PHA has sufficient budget authority to proceed and has complied with 24 CFR § 983.6(d), which governs the selection of PBV proposals. This requirement aims to ensure compliance with the Final Rule published on June 25, 2014, which requires that housing authorities submit information to their HUD Field Office for review prior to issuing an RFP or making an alternative selection for PBV. The notice reviews the process for submitting that information.
The notice also includes instructions for PIC reporting for project-based voucher families. It continues to require that the VAMC or CBOC provide documentation in support of the project as a precondition for considering any request for project-basing.