CLPHA supports the nation’s largest and most innovative housing authorities by advocating for the resources and policies they need to solve local housing challenges and create communities of opportunity. We frequently champion our members' issues, needs, and successes on the Hill, at HUD, and in the media. In these arenas CLPHA also advocates for legislation and policies that help our members, and the public and affordable housing industry as a whole, strengthen neighborhoods and improve lives.
Click below for links to congressional testimonies, statements for the record, action alerts, comments to HUD and other federal agencies, and the latest information about CLPHA's multi-pronged housing advocacy.
In February, the House of Representatives passed H.R. 7024, The Tax Relief for American Families and Workers Act of 2024, which received overwhelming bipartisan support. The bill includes two Low-Income Housing Tax Credit (LIHTC) provisions that would restore the 12.5% allocation increase for 2023 to 2025 and lower the 50% bond financing threshold to 30% for Private Activity Bond allocations made in 2024 to 2025. The bill also includes a $33 billion expansion of the Child Tax Credit (CTC) for the next three years. While the CTC in this bill is not as generous as the 2021 provision included in the American Rescue Plan, this expansion and continuation of the program acknowledges that the benefits provided by the CTC should be continued. The legislation faced various roadblocks in the Senate, including opposition from Senate Finance Committee Chair Mike Crapo (R-ID) due to the CTC provisions included in the bill. However, ongoing discussions are still happening to possibly move the bill forward for a floor vote. We strongly ask that CLPHA members continue to reach out to your Senators and urge them to pass H.R. 7024, the Tax Relief for American Families and Workers Act of 2024.
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ACTION: When asking your Senator to support the Tax Relief for American Families and Workers Act of 2024, mention the importance of, and share your support for, the two LIHTC and CTC related provisions in the bill and ask that the housing provisions are retained in the Senate: LIHTC provisions:
CTC provisions:
The ACTION Campaign, where CLPHA is a Steering Committee member, has prepared background and advocacy materials about the Tax Relief for American Families and Workers Act of 2024. |
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On February 1, 2024, the House of Representatives passed H.R. 7024, The Tax Relief for American Families and Workers Act of 2024 which includes two Low-Income Housing Tax Credit (LIHTC) provisions that were also included in the Affordable Housing Credit Improvement Act (H.R. 3238/S. 1557). According to Novogradac, the provisions which would restore the 12.5 percent allocation for 2023-2025 and lower the 50 percent bond financial threshold to 30 percent for 2024-2025, would finance more than 200,000 additional affordable homes. The bill still needs to be considered by the Senate, which faces several challenges, including a busy legislative agenda for February. Members of the Senate have also floated the idea of scheduling a potential markup of the bill which could potentially amend the legislation and further delay any vote to bring the bill on the Senate floor. The Tax Relief for American Families and Workers Act may also be the last opportunity for Congress to pass any tax related provisions until 2025. The ACTION Campaign, where CLPHA is a Steering Committee member, has prepared background and advocacy materials about the Tax Relief for American Families and Workers Act of 2024.
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ACTION:
For questions or additional information, contact Gerard Holder, CLPHA Legislative Director at gholder@clpha.org. or Cynthia Cuestas, CLPHA Legislative Assistant, at ccuestas@clpha.org. |
Congress Needs To Increase Public And Affordable Housing Funding |
Background: The federal government is currently funded under a continuing resolution (CR) that expires December 16 this year. If the government does not take additional action it runs out of money and has to shut down. Given the uncertainty of what will happen in the appropriations process during the next Congress beginning in January, it is critical that the current Congress finish the work already begun and pass a full year FY23 appropriations bill. CLPHA is particularly concerned with the Transportation, Housing and Urban Development, and Related Agencies (THUD) proposed legislation currently in final negotiations between the House and Senate. CLPHA and industry partners recently sent a letter and revised joint appropriations request to the leadership of the House and Senate appropriations committees asking for specific funding levels and authorizing language be included in the final THUD appropriations bill. Among our requests, we ask Congress to increase funding for the HUD defined shortfalls in the public housing operating fund program to $345 million to accommodate all eligible housing authorities. We ask the committees to accept the Senate-proposed level of $364 million in set-aside funding for tenant protection vouchers (TPVs) since HUD recently indicated that the current demand for TPVs has exceeded its initial projections for FY23 and they again anticipate not being able to fund replacement TPVs for vacant units in calendar year 2023 without additional funding. We also ask that HUD be directed to determine the impact of recent changes to the calculation of FY23 Fair Market Rents (FMRs), because of the recent extension of regulatory waivers increasing payment standards up to 120 percent of the FMR in local housing markets affecting the need for additional housing assistance payments (HAP) set-aside funding.
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ACTION: CLPHA is calling on members to: 1) Ask your Members of Congress to support the recommendations included in the public housing industry joint funding request and joint industry letter. 2) Ask your Members of Congress to support the THUD funding bill. 3) Ask your Members of Congress to support final passage of a full-year FY23 appropriations bill.
For questions or additional information, contact Gerard Holder, CLPHA Legislative Director at gholder@clpha.org. |
BACKGROUND: CLPHA and our industry partners today sent a letter (and attachments Exhibit 1 and Exhibit 2) to House and Senate Appropriations Committee members asking to include legislative language that prevents HUD from implementing unilateral changes to the ACC in the forthcoming FY23 appropriations bill. This joint industry request was made by CLPHA, the MTW Collaborative, the National Association of Housing and Redevelopment Officials (NAHRO) and the Public Housing Authorities Directors Association (PHADA). CLPHA and our industry partners remain concerned that HUD’s continued attempts to revise the ACC will circumvent the Administrative Procedure Act (APA), unilaterally change the contractual relationship between HUD and public housing agencies (PHAs), and strip PHAs of their ability to challenge HUD’s breach of contract actions, which PHAs have recently successfully litigated. Without the inclusion of the legislative language mentioned in our letter, we are concerned that HUD’s ability to make problematic changes to the ACC has been renewed. This week the full House passed six appropriations bills including its version of the FY23 HUD bill. Since the Senate has not yet taken action on their bill version, we hope to have the ACC language included in the Senate bill, and we are seeking eventual conference committee action between the House and Senate to include the ACC language and committee report language. |
ACTION: We are asking housing authorities to sign and send a similar letter asking their representatives in both the House and Senate to reinstate the legislative language regarding the ACC in the General Provisions section of the FY23 HUD appropriations legislation. We’ve drafted a sample letter as a guide for you.
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If you have any questions, contact Gerard Holder, CLPHA Legislative Director, at gholder@clpha.org. |
KEEP HOUSING FUNDING IN BUILD BACK BETTER
Negotiations and progress on enacting Build Back Better legislation have reached an impasse, and Senate opponents to the bill, as written and passed by the House, have indicated they prefer a slimmed down, reduced funding bill.
Consequently, CLPHA has been made aware that funding for housing programs is, once again, at serious risk of being removed from the Build Back Better Act.
The housing investments in this economic recovery package is expected to help make transformational improvements in the lives of low-income and vulnerable Americans and in our communities.
Last week, CLPHA and other national organizations advocating for public housing and related programs sent a letter to the House and Senate leaders asking that housing be retained in Build Back Better or any related reconciliation vehicle.
The housing investments in this economic recovery package are expected to help make transformational improvements in the lives of low-income and vulnerable Americans and in our communities.
ACTION:
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We are asking housing authorities and housing organizations to sign on to a similar letter to Congressional leaders urging them to retain funding for the Public Housing Capital Fund and Housing Choice Vouchers in the Build Back Better legislation.
Sign-ons are Due by February 4!
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CLPHA has been made aware that funding for housing is at serious risk of being removed from the Build Back Better Act under consideration in the budget reconciliation negotiations currently underway in Congress and the White House.
The House Financial Services Committee on September 14 provided $327 billion in funding for affordable housing and community development programs to be included in the President’s Build Back Better Act. The housing investments in this economic recovery package is expected to help make transformational improvements in the lives of low-income and vulnerable Americans and in our communities.
The negotiations are on a fast track and taking place at the highest levels between the House and Senate leadership, key members of Congress, and the White House. We understand Congress and the White House have not heard from housing stakeholders on the importance of keeping housing in the legislation.
We have been told that the next 48 hours are critical to keeping housing in the legislation.
Since housing is very much on the chopping block, we encourage CLPHA members to:
Reach out to your representatives in the House and Senate and ask them to contact their leadership and express support for retaining the housing provisions in the Build Back Better Act.
We cannot overstate how important it is for you to contact your Congresspersons and Senators and have them communicate with their Leadership and the White House that
HOUSING MUST BE INCLUDED IN THE BUILD BACK BETTER ACT!
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Important Talking Points Include:
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1 Public Housing Stimulus Funding: A Report on the Economic Impact of Recovery Act Capital Improvements, Commissioned by PHADA, CLPHA and NAHRO with funding from the Housing Authority Insurance (HAI) Group, 2011.
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- Reach out to your Member of Congress.
- Explain why the SAVE Act is important to your public housing authority, your residents and your community.
- Urge your member of Congress to support the SAVE Act when it is re-introduced in Congress.
Deadline: 5:00 PM ET Tomorrow, March 26
Urge your members of Congress to cosponsor H.R. 1904: The Broadband Justice Act of 2021. The COVID-19 pandemic has highlighted the growing digital divide and the deepening disparities among access to essential technology. These inequities especially impact lower income households and those living in federally assisted housing.
By updating the definitions used by HUD, the Department of Treasury, and USDA for utility allowance, The Broadband Justice Act of 2021 would bring affordable broadband to 8 million households residing in federally assisted housing throughout the nation. Bolstered through the creation of a new grant program to develop the required infrastructure and additional operating funds to mitigate increased costs, access to broadband as an allowed utility would be federally subsidized, in a similar way that gas, electricity, and water currently are. Congressman Bowman (D-NY), the bill sponsor, is organizing support for the letter and has set a Friday, March 26, 5:00 pm ET deadline for House members to sign on.
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ACTION:
1) CLPHA is asking you to strongly encourage your Members of Congress to cosponsor H.R. 1904: The Broadband Justice Act of 2021.
2) Your Member of Congress should fill out this form to cosponsor the bill.
For additional information, please email Josh Shokoor, CLPHA Research & Policy Analyst, at jshokoor@clpha.org.
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Congressional Democrats are moving the next COVID-19 bill swiftly through Congress. CLPHA and other national public housing industry groups are asking our members to sign on to a joint industry letter to be sent to congressional leadership asking for additional emergency funding and longer-term preservation resources for public housing operating funding, housing vouchers, and infrastructure funding.
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Sign-on for the letter is on a short deadline with
sign-on due by 12:00 p.m. ET Friday, February 12.
Therefore, CLPHA is calling on members to re-double efforts to ensure our funding requests are considered by Congress and included in the next economic stimulus package.
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- Communicate with your Members of Congress and ask them to support including emergency funding and longer-term preservation resources for public housing, housing vouchers and infrastructure in the next COVID relief legislation.
- Ask your Members of Congress to urge the House and Senate Leadership to include emergency funding and longer-term preservation resources for public housing, housing vouchers and infrastructure in the next COVID relief legislation.
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HUD Welcomed IT Working Group Feedback
HUD has rescinded Notice PIH 2024-12 and will issue guidance once it has revised the HIP implementation schedule. The implementation schedule of the new Housing Information Portal (HIP), the replacement for IMS/PIC, will be revised and critical dates will be extended. A new schedule is necessary to ensure that programs do not experience interruptions in service or potential delays. Additionally, HUD is resolving technical issues encountered in the initial testing phase of HIP. To ensure HIP's implementation success, HUD is consulting with PHA software vendors on the new schedule. HUD first shared this news with the IT Working Group, and it will share the revised schedule and updated guidance with us soon.
HUD acknowledges it has heard CLPHA's feedback, particularly through the IT Working Group. HUD is working to revise the HIP implementation schedule and will provide more information on the transition to HIP. Software vendors will be consulted on the new schedule to ensure successful implementation.
Actions PHAs Should Continue
In the meantime, PHAs should continue preparing for the transition to HIP by carrying out the actions listed below:
- PHAs should continue to clean up data and ensure data accuracy.
- PHAs should continue submitting HUD-50058 forms and maintaining their physical inventory as they normally would.
- The Special Applications Center will accept and process inventory removal applications as usual. PHAs should continue to follow submission instructions as provided in Notice PIH 2021-07 and 24 CFR 970.
Applicable Guidance
Though Notice PIH 2024-12 is rescinded, the following HUD guidance remains applicable:
- HUD will adjust the rollout of the Enterprise Management Voucher System (eVMS) based on the revised HIP schedule. There are no changes to Notice PIH 2024-16. For more information on the eVMS implementation and schedule, visit HUD’s eVMS web page.
- HUD will rely on IMS/PIC data as of the reporting date of February 29, 2024, to support the calculation of FY 2025 Capital Fund grants as outlined in HUD’s Office of Capital Improvements web page.
- CY 2025 Operating Fund grants will be determined based on data from IMS/PIC during the normal Operating Fund reporting period of July 1, 2023, through June 30, 2024. See Notice PIH 2023-25.
HOTMA Sections 102 and 104
As stated in Notice PIH 2023-27 entitled “Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA),” PHAs must be able to submit transactions to HIP in order to comply with sections 102 and 104 of HOTMA. HUD will provide future guidance regarding a timeline for compliance with sections 102 and 104 of HOTMA.
Because HOTMA-compliant reexaminations cannot be successfully submitted to IMS/PIC, HUD advises PHAs not to begin conducting reexaminations under HOTMA rules without further information on when the HOTMA-compliant HUD-50058 in HIP will be available.
CLPHA, along with Reno & Cavanaugh PLLC, submitted comments on the Reducing Barriers to HUD-Assisted Housing Proposed Rule. The comments are based on members’ feedback gathered via a survey and a listening session. We greatly appreciate the input of all members who participated in the feedback collection process.
The comments are rooted in CLPHA’s commitment to addressing housing inequities by integrating a racial equity lens with our policy agenda. Our commitment to racial equity and increasing access to housing is balanced by the need for PHAs to have the flexibility to respond to local needs, priorities, and requirements without unduly burdensome and unnecessarily prescriptive mandates. Therefore, our comments on the Proposed Rule not only reflect the racial equity lens through which we approach screening and admissions policies and the feedback we gathered from our members, but also are informed by the heavily regulated and under-financed environment PHAs must operate in.
As a preliminary matter, HUD must first clarify what “criminal activity” triggers the 12-month time frame. We encourage HUD to adopt a sliding scale time frame that corresponds to the severity of the criminal activity. We encourage HUD to amend the “presumptively unreasonable” standard to a sliding scale time frame that corresponds to the severity of the criminal activity. In other words, the more violent the crime, the longer the lookback period PHAs may reasonably apply.
Additionally, we argue that if HUD requires an additional 15-day notice period for applicants to provide additional mitigating information, the additional administrative burden, costs, and delays in processing applicants should be accounted for in HUD’s policies, regulations, and performance measures. The letter goes on to respond to all of the questions posed by HUD in the proposed rule.
The compliance date for NSPIRE-V has been delayed by one additional year until October 1, 2025. The announcement was sent to PHA executive directors today by Principal Deputy Assistant Secretary Richard J. Monocchio.
The original NSPIRE-V notice will soon be re-issued with updated information in light of the extension. HUD published the original NSPIRE HCV Administrative Procedures notice on September 29, 2023. PHAs should also watch for an announcement in the Federal Register once the HCV extension is final.
PHAs that have existing approvals for acceptability criteria variations will still need these approvals reviewed by HUD, but this deadline is extended to before October 1, 2025. All current acceptability criteria variations and alternate inspection methods can remain in place until HUD completes the review unless they included approval of fuel-burning space heaters. Approval of their use as a variation concluded on January 1, 2024. PHAs with questions on variations can email NSPIREV_AlternateInspection@hud.gov.
Soon, HUD will update the NSPIRE Smoke Alarm standard to implement the requirements enacted in the Consolidated Appropriations Act, 2023, for either hard wired or sealed, 10-year batteries smoke alarms. PHAs will be required to be in compliance with this new standard before December 23, 2024, even if they are still under the previously defined HQS standard.
The Visual Assessment Standard for Potential Lead-Based Paint Hazards still applies, as NSPIRE did not revise the existing requirements under 24 CFR Part 35 Subparts M (Tenant-based Rental Assistance) and H (Project-based Assistance).
PHAs should also note that the NSPIRE Standard for Carbon Monoxide Alarms will still apply during this extension, because it implements Congressional requirements already in effect.
CLPHA will keep its members up-to-date on NSPIRE-V as soon as the updated Notice and Federal Register announcements are published.