HUD issued PIH Notice 2020-17 and 2020-18 today, which outline the methodology and process for awarding supplemental HAP and administrative fees for the Housing Choice Voucher Program provided in the CARES Act. CLPHA communicated often with HUD that our members need these funds to cover lost rent revenue and that the Congressional intent in the CARES Act was to deliver the funds as quickly and efficiently as possible.
HAP Funds
To be eligible for the $400 million in supplemental HAP funding, PHAs must be eligible in one of two categories: 1) “Extraordinary Circumstances,” where the PHA has experienced a significant increase in voucher per unit cost (PUC) due to extraordinary circumstances related to the pandemic, or 2) "Shortfall Funds," where despite taking reasonable cost saving measures, the agency would otherwise be required to terminate rent assistance due to insufficient funding. MTW agencies are also eligible under each category.
HUD will accept applications under Extraordinary Circumstances through October 31, 2020 and review applications on a rolling basis. PHAs qualify to receive supplemental funds under Extraordinary Circumstances if their PUC, based on the most recent available month’s data, is 102% or greater than the PUC used to determine the PHA’s 2020 renewal funding.
PHAs that qualify for priority status under Extraordinary Circumstances, in which PHAs also have less than three months of HAP reserves, will receive funding shortly after HUD processes the application. For PHAs with applications that do not qualify for priority status, HUD will notify the PHA that their application has been approved but PHAs will not receive the funds until November.
The period of availability for the HAP supplemental funding under Extraordinary Circumstances is March 27, 2020 through June 30, 2021.
HUD will accept applications under Shortfall Funds for PHAs who are 1) already in a Shortfall Prevention Team (SPT)-confirmed shortfall as of March 31, 2020, or 2) are confirmed to be in a shortfall by HUD after March 31, 2020. PHAs who previously applied for shortfall funds through the FY2020 set-aside under PIH Notice 2020-04 do not need to reapply as HUD will automatically process that request under this notice. The application period will remain open.
The period of availability for the HAP supplemental funding under Shortfall Funds is March 27, 2020 through December 31, 2020.
Admin Fees
HUD will allocate the $472 remaining supplemental admin fee funding to PHAs, including MTW agencies, as a single disbursement in August 2020. The funding, equivalent to approximately 2.35 months of admin fee eligibility, will be allocated to PHAs by multiplying the total unit months leased per VMS for May 2020 times 2, prorated at approximately 117% in order to distribute the funds equally among all PHAs.
The notice reviews eligible activities for the supplemental admin fees and clarifies language about eligible activities from the first round of supplemental admin fees in PIH Notice 2020-08. The period of availability for admin fees under this notice is through June 30, 2021, and HUD has extended the period of availability for the first round of supplemental admin fees through June 30, 2021 as well.
Please see the notices for additional detail and instructions about how to apply. CLPHA will review the notice in detail and provide further analysis shortly. For questions about the notices, contact Research & Policy Manager Emily Warren at [email protected].
On August 11 at 2:00 p.m. ET, CLPHA will join Mobility Works, the Center on Budget and Policy Priorities, Opportunity Insights, and NAHRO in co-sponsoring a webinar that reviews key details of HUD’s Mobility Demonstration Notice. The webinar will feature presentations by CLPHA members, including Andrew Lofton, Executive Director of the Seattle Housing Authority and Jeffery Patterson, CEO of the Cuyahoga Metropolitan Housing Authority. Register for the webinar here.
A brief description of the mobility notice is available here. To support members applying for the demonstration, we invite you to contact us about any other events that CLPHA could offer to applicants as they build their applications. Please contact Research & Policy Manager Emily Warren with any thoughts or feedback at [email protected].
Applications Due December 14
Tomorrow, HUD will publish a notice in the Federal Register that outlines the research design, eligibility criteria, application process, and requirements for its housing voucher mobility demonstration. HUD estimates that the demonstration, which received $25 million each in FY19 and FY20 appropriations, will provide mobility-related services to approximately 9,500 families with children.
CLPHA members have been at the forefront of developing and implementing innovative mobility strategies. This demonstration will provide an opportunity for more housing authorities to engage in mobility efforts. In 2018, CLPHA co-sponsored the National Conference on Housing Mobility, bringing together practitioners, researchers and policy makers to expand mobility initiatives across the country. CLPHA will be co-sponsoring a webinar with national partners on the mobility demonstration. Once the date is set, CLPHA will notify our members.
The demonstration will be implemented over a six-year period. Families participating in the demonstration will be randomly assigned to a control group or one of two treatment groups - a group receiving full mobility services and a second group receiving lighter-touch services. To conduct a valid randomized study, HUD estimates that PHAs participating in the demonstration will need to serve a minimum of 1,950 families across treatment and control groups. Applications for the demonstration are due by 11:59 p.m. (EDT) on December 14, 2020.
Most of the demonstration funds will be used for mobility-related services, with approximately $10 million of those funds being used for 1,000 new vouchers. Due to the small number of new vouchers, participating PHAs must make their existing vouchers available for demonstration families as vouchers turn over. HUD estimates that PHAs will need to make available for use in the demonstration approximately half of the number of vouchers they are awarded through the demonstration.
Families participating in the demonstration will primarily be existing voucher holders, but some families will be new admissions. Participating PHAs will adopt a waiting list preference for families who meet the demonstration criteria of having at least one child aged 13 and under and living in a census tract with poverty rate of 30 percent or higher.
PHAs can be eligible to apply under four eligibility criteria, some of which may require multiple PHAs applying together with one PHA designated as the lead PHA:
- PHAs that together serve areas that contain high concentrations of voucher holders within low-opportunity areas and have an adequate number of moderately priced rental units in high-opportunity areas.
- PHAs in a planned or partial consortium of PHAs that includes at least one PHA with a high-performing FSS program.
- PHAs in a planned or partial consortium that includes one or more small PHAs that will together run a consolidated mobility-focused operation.
- A single PHA that serves areas containing high concentrations of voucher holders within low-opportunity areas and has an adequate number of moderately priced rental units in high-opportunity areas.
Other eligibility requirements include establishing a waitlist preference for eligible families, adopting payment standards adequate for attracting landlords in high-opportunity areas, and participating in the demonstration’s evaluation.
HUD expects to announce awards in December 2020 and make between 5-10 awards to PHAs for a combination of new vouchers and mobility services, with individual awards totaling no less than $4 million and no more than $10 millionn.
HUD has created a mobility demonstration webpage with additional resources, including registration links for two webinars on July 29 and August 5 in which HUD staff will review the demonstration requirements, evaluation, and application process.
CLPHA will provide additional analysis of the notice shortly. For questions about the notice, contact Research & Policy Manager Emily Warren at [email protected].