In a recent memo, HUD instructs Field Office staff to continue accepting applications for the CIAP formula grants well beyond the official deadline. The deadline for agencies to apply for CIAP funds was originally listed as August 26 (see previous alert below).
The document which was forwarded to HUD staff says that they should not cut off applications on August 26. "In order to ensure that all CIAP eligible PHAs have adequate opportunity to apply for their formula share of FY 1999 CIAP funds, it may be necessary to continue accepting applications well into September," the memo says.
Field Offices are further instructed that starting August 27, they should contact CIAP eligible PHAs "who have not applied or who have not previously contacted you regarding late submissions to see if they need assistance in finalizing their applications."
PHADA alert from August 26
PHADA sends letter protesting false CIAP deadline
HUD recently posted a notice (PIH-99-38) providing guidance and instructions for small PHAs to apply for CIAP formula funding. Fiscal Year 1999 is the first year CIAP-eligible agencies will be funded through a formula allocation. The HUD notice included a "false" application deadline that would likely cause confusion and could even deter some HAs from applying for these funds. PHADA sent the following letter to HUD regarding this issue.
The CIAP notice is available through the HUD web site at http://www.hud.gov/pih/publications/notices/notices.html.
August 26, 1999
Honorable Harold Lucas
Assistant Secretary
Office of Public and Indian Housing
Department of Housing
and Urban Development
451 7 Street S.W.
Washington, DC 20410
Dear Assistant Secretary Lucas:
At the HUD web site this past Tuesday, we found Notice PIH 99-38 (HA) regarding submission of applications for the CIAP program. The deadline for response is rather surprising. The issue date was August 20, it was posted on the web on August 23, and the deadline for submissions is today, August 26, 1999. If you consider that the target HAs are the smallest and many probably lack internet capability and that regular mail will probably not reach them until after the deadline, I trust you will agree the timing is unreasonable.
In response to our telephone inquiry, PIH staff informed PHADA that the deadline is not "real" but is designed to send a wake up call to the affected HAs. The later they apply, the later they get their money. Apparently, Field Offices have been told to accept applications after the deadline as they come in. Unfortunately, the HAs themselves have no way of knowing the deadline is not firm. In addition, it is conceivable that some HAs may never apply, mistakenly believing they have missed the "deadline" and therefore are no longer eligible for the capital funds.
In PHADA's view, this is an inadvisable way of doing business. We would instead like to recommend you reissue the notice with a real (and reasonable) deadline in the best interests of HUD, HAs and the residents they serve. Thank you for your consideration of PHADA's views.
Sincerely,
Timothy G. Kaiser
Executive Director
