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President’s Forum: HUD Regulations, Requirements Should be Eased So HAs Can Focus on Residents’ Needs

In addition to the suggestions in President John Hodge’s letter to Secretary Carson, PHADA recommended the following items below to HUD. The association urged the Department to rapidly develop expedited procedures, including the use of blanket waivers, to address matters such as:

  • Unused HCV budget authority due to the time voucher holders are unable to shop for housing,
  • Holding HCV programs harmless from declining utilization for 2021 allocations,
  • Allow extensions beyond 120 days for voucher holders to shop,
  • Accept self-certification of matters affecting eligibility and rents and broad acceptance of EIV information as adequate income verification,
  • Accept self-certification of HQS compliance at least for annual reinspections of occupied units if not for initial inspections as well,
  • Adjust PHAS scores or suspend PHAS for the current program year, for example due to increased vacancies or decreased rent collections,
  • Adjust SEMAP scores or suspend SEMAP for the current program year, for example due to difficulties conducting HQS inspections on time,
  • Accept annual recertifications that extend beyond 12 months, and
  • Waive both the obligation and expenditure deadlines for Capital Grant Program funds.

PHADA also said HUD should seek the statutory approval of Congress for blanket waivers if that is not an option under the current national emergency. Similarly, PHADA urged HUD to consider requesting general congressional authorization to waive statutory requirements currently excluded from the Secretary’s waiver authority for the duration of the currently declared national emergency.

PHADA President John Hodge

These are unprecedented times. Dealing with the coronavirus outbreak is understandably our highest priority as we all work to preserve the health and safety of the residents and staffs in our communities. As always, PHADA can help be our voice in Washington and advocate for our needs to those at HUD and on Capitol Hill. With this in mind, I recently wrote to HUD Secretary Ben Carson on the public health crisis, and our staff sent similar communications to Congress. PHADA’s complete letter can be found here.

The association has asked HUD to take all necessary steps to waive or suspend rules and regulations that require actions by HAs and/or their residents to engage in personal interactions, or to complete steps and tasks that cannot be effectively completed because of the adoption of social distancing practices. Specifically, we have urged the Department to immediately waive or suspend various activities/requirements/regulations until further notice, or until further guidance is provided and the Centers For Disease Control or other authorities.

PHADA’s letter noted that in-person contact with inspectors is a concern for many seniors and those with compromised health. Given the dire consequences of the virus, it seems obvious that all inspection-related requirements be temporarily waived to minimize risks to assisted households. To HUD’s credit, it announced on March 13 that all REAC inspections would be suspended. 

The Department should go further than this modest step. In addition to all REAC and NSPIRE physical inspections, we advocated that the requirements for HQS and UPCS annual inspections to be completed at least once every 12 months be lifted, too. To further minimize personal interactions, PHADA also asked that annual and interim recertifications/redeterminations be eased as well.

For the foreseeable future, it will be very difficult for many HAs to operate in normal ways, and HUD’s regulatory regime should reflect this new reality. Consequently, we recommended that all SEMAP and PHAS scoring be waived for 2020 and that all public meeting requirements relating to annual plans be suspended. Similarly, we are asking for flexibility from obligations and requirements relating to ongoing HUD submissions, including PIC, VMS, EPIC, and any and all electronic reporting mechanisms. HUD should also extend deadlines for any and all other submissions, including competitive grant applications, grant or other reports, rulemaking comments, and annual plans.

For the foreseeable future, it will be very difficult for many HAs to operate in normal ways, and HUD’s regulatory regime should reflect this new reality.

All of PHADA’s suggestions are designed to minimize risks to residents as well as housing agency employees. As we all know quite well, a significant portion of our households are seniors, persons with disabilities and veterans, all of whom may have concerns about leaving home and/or coming into contact unnecessarily with others, including traveling on public transportation to our offices.

Like Federal employees including those at HUD, many of us have been told to it would be advisable to conduct business remotely to the maximum extent possible. Conducting business remotely is a challenge. For example, for residents to mail in their documentation for annual recertifications could be a financial and physical hardship if they must leave home to have copies of documents made and then send those in to HAs. For families with children, many of the children may be home from school and it would not be practical for them to go to the HA. Again, HUD requirements need to be more flexible to address these situations. 


Budget Concerns

At this stage, it is hard to tell, but the financial impact to our programs could be significant. Many HAs may experience unanticipated decreases in tenant rents/leasing in HCV and decreased tenant rents and increased utilities in public housing (in addition to potential increases in operational costs). Those changes would squeeze this year’s budgets and would need to be accounted for in FY 21 funding. Ensuring this adequate funding will be a top PHADA priority.


Please Provide PHADA With Local Response Plans

Every locality is unique. If you or your region or state has concerns that the PHADA letter does not address, please inform our Washington staff.

As communities across the country respond to COVID-19, public housing agencies also seek to mitigate risk to their client households and employees from the spread of the disease. HAs are conducting emergency planning to counter the global pandemic and PHADA aims to support members in these endeavors. To this point, PHADA is developing a resource library to include information from public health experts, HUD, and other partners to ensure HAs are informed of recommended practices.

If your agency has completed its planning, we are requesting you share any documents with PHADA so that we can make them available to your colleagues in the industry.If you are willing to participate in this effort, please send them to our Director of Communications, Blake Stenning at: bstenning@phada.org.


Status of PHADA’s Annual Convention in Denver

At this time, PHADA’s Annual Convention & Exhibition is proceeding as planned for May 31–June 3. Please look for registration and other information on our website.

Obviously, this is a quickly evolving situation and the status of our meeting is subject to change. Please be assured that the PHADA leadership is monitoring the situation carefully and following guidance from the World Health Organization (WHO), the U.S. Centers for Disease Control and Prevention (CDC), and local authorities. The health and safety of our attendees, partners and staff is our priority and we will continue to provide updates as the situation unfolds. I am hoping to see many of you in Denver. Regardless, I hope you remain safe and well. Let me know if there are more ways PHADA can be of service to you during this challenging time.