CLPHA Advocacy

Today, CLPHA and our counsel Reno & Cavanaugh, PLLC sent a letter to HUD Secretary Ben Carson outlining our comments and concerns about HUD’s recent waiver notice. We also suggested amendments and asked for clarification on several key points of the notice.

Our letter included the following suggestions and questions to HUD regarding the notice:  

• Extend the Periods of Eligibility for all waivers to sufficiently account for the ongoing and extended nature of the COVID-19 pandemic. 
• Amend the effective date in the waiver notice to grandfather in PHAs that prioritized the health and safety needs of their staff, residents, and properties prior to April 10, 2020 and did not pursue individual COVID-19 waiver requests in accordance with HUD’s written guidance. 
• Ensure coordination among HUD offices to ensure PHAs are provided with a consistent, uniform set of waivers across programs that allow for the maximum relief permitted by law. 
• Provide PHAs with waivers of additional reporting requirements under HUD’s Voucher Management System and Cash Management and should clarify or expand its existing waiver of significant amendment public notice requirements to cover significant amendments of Administrative and Continued Occupancy Policies and Section 8 Administrative Plans. 
• Expand Waiver HQS-10: Housing Quality Standards; Space and Security to apply to initial tenancies under HUD’s project-based voucher program. 
• Offer additional guidance on resident notice requirements of waivers being used and PHA's current authority to waive or defer rents. 
• Allow PHAs to use available Public Housing Operating Funds and Section 8 Housing Assistance Payment Funds appropriated in the CARES Act towards the provision of internet services as they are an essential utility required to support or maintain the health and safety of assisted individuals and families, support education, and help PHAs respond to the COVID-19 pandemic. 
• Work with PHAs to clarify existing personally identifiable information (PII) requirements and seek ways to permit PHAs to share PII with service providers for the purposes of facilitating access to food, medicine, childcare, and other supportive services for assisted households. 
• Clarify the citations contained in the waiver notice and to issue technical corrections as needed to fix errant citations to statutory and regulatory authority. 

CLPHA thanks our members for the insights they shared with us on the waiver notice, and we will keep members informed about our future communications with HUD on COVID-19 statutory and regulatory waivers. Please email CLPHA Sr. Research and Policy analyst Emily Warren at ewarren@clpha.org with any questions about our letter to HUD or the waiver notice.

Read Our Letter to HUD 

However, the joint letter is not enough!

It is critical that you follow up with your representatives and stress the need for providing additional resources to housing authorities as you work to deal with this devastating health and economic crisis.

Without your active engagement with your Members of Congress, policymakers on Capitol Hill will give lower priority to providing additional resources to housing authorities.

CLPHA is calling on members to step up efforts to ensure our funding requests are considered by Congress and included in the next economic stimulus package.

CLPHA strongly urges members to: