Seth Embry and Jim Armstrong, PHADA Policy Analysts
Late on Friday, April 10, HUD published Notice PIH 2020-05 entitled, “COVID-19 Statutory and Regulatory Waivers for the Public Housing, Housing Choice Voucher, Indian Housing Block Grant and Indian Community Development Block Grant programs, Suspension of Public Housing Assessment System and Section Eight Management Assessment Program.” This Notice implements waivers authorized by the CARES Act which was enacted on March 27. PHADA, other associations, and HAs encouraged Congress to include this waiver authorization due to HUD’s historic reluctance to use its existing regulatory waiver authority for any but the least important issues or to issue blanket waivers only under the direst circumstances. Congress authorized the Secretary to waive statutory as well as regulatory requirements that, “are necessary for the safe and effective administration of these funds, consistent with the purposes described under this heading in this Act, to prevent, prepare for, and respond to coronavirus.”
Available Waivers Are Only A Start
In issuing Notice PIH 2020-05, HUD has taken an important early step to help HAs (and the Department) manage assisted housing programs in the midst of the COVID-19 pandemic. These published waivers are broad and substantive, and HUD has minimized the administrative burdens facing HAs as they choose which waivers will be of benefit to them and to their program participants. HUD will permit HAs to implement waivers without any additional federal reporting or approvals for this significant set of blanket waivers. It is also helpful that HUD has made clear that all of these waivers are optional, as is the timing of waivers within the time frames described for each waiver. HAs should find that flexibility very helpful as they tailor their decisions to local needs.
The notice does leave several matters unaddressed. It seems clear that HUD anticipates the primary impacts of the pandemic to have abated significantly by the end of July since many of these waivers will expire at that time. HUD’s expectation seems optimistic and speculative. There have been significantly different opinions on the timing of returning to normal operations, and much about this novel coronavirus and its disease remains unknown. The virus appears to be much more contagious than originally thought, exposed individuals seem to spread the virus well ahead of the appearance of symptoms, and some localities may be entering a second wave of virus infections. Experts have speculated that the virus may abate with the arrival of warm weather and then reappear again in the fall as seasonal influenza does, and vaccinations for the novel corona virus will probably not be available until 2021. Given the uncertainties surrounding COVID-19, HUD might have been wiser to issue more open ended or longer lasting waivers and announce the end of specific waivers at some time in the future. The Department may need to extend all of its deadlines later in the summer, a step that will tend to add to confusion concerning the timing and longevity of some waivers.
In addition, there are confusing elements in some of HUD’s waiver descriptions. One instance involves the lack of clarity surrounding the Community Service and Self-Sufficiency waiver and what happens to eligible participants as the waiver expires. That problem is described below. Another issue involves PHAS and SEMAP scoring after those waivers expires. When both assessment systems restart, what will HUD use for scoring? Does the Department expect, after many months of pandemic related social distancing, stay at home and quarantine orders, that metrics on which PHAS and SEMAP scores are based will be unaffected? The waiver descriptions generally do not speak to these questions.
Fortunately, HUD chose to issue blanket waivers in response to this authority, and to implement those waivers without any requirement that HAs notify the Department concerning the waivers they elect to use (unlike in previous disaster response situations). In implementing any waiver, HAs are required to:
- Maintain records of which waivers were implemented, and the dates they were effective.
- Maintain compliance with local board approval and oversight requirements (unless waived).
- Provide resident notification of changes in policies resulting from waivers the HAs choose to implement.
Implementation of waivers is voluntary and HAs should choose to use those that are appropriate to their local needs. HAs may choose to end their use of waivers earlier than the expiration date outlined in the notice.
Unfortunately, several of the waivers effectively backload work for HAs to the end of 2020 or early in 2021. Delayed annual reexaminations must still be completed by the end of the year in addition to the standard reexamination workload. The sooner the pandemic abates, the less these timing issues may cause concern, but the Department should consider the uncertainty regarding COVID-19 and it would be very helpful if HUD addressed contingencies surrounding potential pandemic trends. Those contingencies may affect whether individual agencies decide to opt for specific waivers or not.
Discussion of Available Waivers
HUD’s notice is organized by program and other topics, and waivers are identified by number. Sections of the notice cover:
- Waivers available for both the public housing and Housing Choice Voucher (HCV) programs,
- Waivers for HCV inspections,
- HCV general waivers,
- Public housing program waivers,
- Waivers of PHAS and SEMAP assessments,
- General administrative relief and streamlining waivers, and
- Native American housing program waivers.
Public Housing and HCV Waivers
PHA Plans (PH and HCV-1)
- Upcoming 5-Year and Annual Plan due dates delayed
- Significant amendment process not required through July
HUD provided substantial relief for HAs with upcoming due dates for 5-Year and Annual Plans, including with regard to the process for implement significant amendments.
HAs with fiscal year end dates (FYEs) in June and September of 2020 are treated as if their fiscal year ends December 31, and thus must submit 5-Year and Annual Plans by October 18, 2020. HAs with FYEs of December 31, 2020, have until January 16, 2021, to submit their plans.
Significant Amendment Requirements
Except for plan changes related to Demolition and Disposition under Section 18, Voluntary Conversion under Section 22, and the Rental Assistance Demonstration (RAD), the requirements are waived. The alternative requirement allows changes to HA plans to be “effectuated without completing the significant amendment process.” This alternative process can be utilized until July 31, 2020.
The notice includes four waivers related to annual and interim reexaminations, verification of income, and EIV requirements applicable to both the public housing and HCV programs. All waivers are available until July 31, 2020, unless indicated.
Delayed Annual Reexaminations (PH and HCV-2)
The standard requirement is for HAs to reexamine families’ circumstances (composition, income, and deductions) at least once each year. HUD will permit HAs to delay annual reexaminations so that they may occur less frequently than once each year (that is, there are more than 12 months between the last and the current annual reexamination). However, for both programs, all annual reexaminations that are due in calendar year 2020 must be completed before December 31, 2020. In addition, for HCV participants, delaying an annual reexamination will not delay implementing increased payment standards using an alternative requirement described elsewhere.
In general, this waiver will help agencies and participants avoid unnecessary contacts required to complete annual reexaminations, but the waiver effectively backloads the work involved in these annual reexaminations. HAs should make sure that delays in the next few months don’t overburden their capacities to complete all 2020 annual reexaminations before December 31. HUD should also reconsider its requirement that HAs complete all of these reexaminations within this calendar year. The Department could permit agencies to simply forgo these reexaminations and recommence their regular reexamination schedule in 2021.
Income Verification (PH and HCV-3 and 4)
- Self-certifications can be used as the highest form of verification to process annual and interim recertifications.
HAs may elect to use the annual and/or interim reexamination waiver and avoid requirements “to use the income hierarchy described by PIH Notice 2018-18 and will allow PHAs to forgo third-party income verification requirements for annual reexaminations, including the use of EIV….”
Notice PIH 2018-18 outlines the verification hierarchy. Tenant certification is an acceptable form of verification according to the notice although it is lowest in HUD’s hierarchy. This waiver appears to suspend requirements to document reasons for using self-certifications in participants’ records.
In its notice, HUD reminds HAs that HUD has never imposed a general requirement for in-person certifications and recertifications, although such meetings may be required as reasonable accommodations for applicants and participants with disabilities. HUD also points out that if self-certifications result in “material discrepancies” related to family composition and income at a later date, HAs will have to take action in accordance with agency policy. Presumably, HAs may need to charge retroactive rent or refund rent overpayments, terminate assistance or leases, and address issues of overhousing and underhousing. PHADA wishes to remind HAs that tenant self-certification has always been and remains an acceptable (although less desirable) form of verification.
Although the notice is silent in regard to verifications for the purposes of eligibility and initial tenant rent, the same verification hierarchy applies and presumably so does the waiver. However, PHADA will seek clarification from HUD on this point. In addition, HUD suggests that HAs may wish to review their policies requiring families to report income changes between annual reexaminations. There are waivers covered in the HCV section below outlining how to expedite policy changes.
EIV Monitoring (PH and HCV-5)
- EIV Monitoring requirements from Notice PIH 2018-18 are waived.
HAs may choose to use this waiver and avoid standard requirements for monitoring various discrepancy reports in the EIV system.
Family Self-Sufficiency Program (PH and HCV-6)
For the duration of 2020 HAs can extend a family’s contract of participation for up to two years using COVID-19 as the “good cause” justification.
Public Housing and HCV Waiting Lists (PH and HCV-7)
HUD is waiving the requirement to publish a notice of waiting list openings in local newspapers. Instead, HAs may provide notice on its website or its general information telephone voicemail message. This requirement is available until July 31, 2020.
Additional Waivers Needed
PHADA continues to make additional recommendations for waivers, including:
- Waive the requirement for documentation supporting eligibility be received with 60 days of voucher issuance (24 CFR 982.201(e)). This will avoid inconveniencing applicants if HAs are delayed in issuing vouchers.
- Clarify that the income verification waivers (PH and HCV-3 and 4) apply to initial certifications.
- Waive the prohibition against tenants receiving local or State housing subsidies at 982.352(c)(8). If needed, tenants should be able to receive emergency assistance to help with costs of living, including rent, if experiencing a hardship. Additionally, it is possible that financial assistance will be provided from States and localities for multiple uses including rent and residents should not avoid or conceal assistance for fear of violating program rules.
- Waive the requirement to accept incoming ports at 982.355(b). In some areas, social distancing and quarantining could make housing searches infeasible. In these areas, it would be an unnecessary burden for HAs, and a great inconvenience for participants, to force HAs to accept incoming ports that cannot be assisted.
- Temporarily increase the upper limit of the payment standard basic range to 120 percent of FMR (982.503(b)) to reduce the need to seek Field Office approval.
- Allow payment standard increases in concert with household composition changes at interim recertifications (24 CFR 982.505(c)(5)). This change would function in much the same fashion as waiver HCV-7.
- Waive the requirement for rent reasonable redeterminations triggered by a 10 percent decrease in FMRs at 982.507(a)(2)(ii) to reduce administrative burden for HAs and avoid potential housing cost increases for families.
- Waive the requirement that initial rent burdens not exceed 40 percent (24 CFR 982.508) to allow families greater housing choice. Understanding the potentially negative impact on families, this waiver could be restricted to currently assisted families already familiar with the operation of the program and the potential risk in such housing burdens.
- Automatically extend Designated Housing Plans due for renewal in CY 2020 until at least December 31, 2020 at Section 7(f) of the 1937 Housing Act (24 CFR 945.203(f)). This waiver is an appropriate accompaniment to the flexibility HUD extended itself in Section 12 of the waiver notice.
Housing Choice Voucher Program Waivers
The Notice contains separate sections for Housing Quality Standards (HQS) inspections and general HCV program waivers. HUD’s HQS waivers are intended to allow HAs to reduce contact between inspectors and other individuals, but do not relive HAs of their obligation to have all occupied units inspected once it is feasible to do so.
HAs that take advantage of HQS waivers to defer inspections can still choose to inspect any currently assisted unit or one for which a Request for Tenancy Approval has been submitted. Additionally, HUD has not provided a waiver from HQS enforcement requirements for assisted units or an owner’s responsibilities for maintaining unit condition. HAs can apply any available HQS waivers to units they own in if the independent entity is unable to perform inspections.
Initial and Biennial Inspections (HCV), Pre-Contract, Biennial, Turnover, New/Substitute Unit Inspections (PBV) (HQS-1, 2, 5, 6, 7, and 8)
- HAs can accept certifications from the owner in lieu of conducting initial inspections prior to executing the HAP/AHAP contract.
- HAs can accept owner certifications until July 31, 2020 but must perform the initial inspections by October 31, 2020.
- HAs can delay any biennial inspection until October 31, 2020.
- HAs can permit assisted households to add persons to occupied units that would exceed the one sleeping area per two individuals limit.
For HCV and PBV units, HAs can accept an owner’s certification that “the owner has no reasonable basis to have knowledge that life-threatening conditions exist in the unit…” in lieu of conducting an initial inspection in order to execute the HAP contract and begin assistance payments. The owner’s certification is also acceptable for any HA-mandated requirements pursuant to a PBV AHAP. HUD’s awkward certification language may be confusing to HAs and owners alike who must interpret and apply the phrase “reasonable basis” instead of utilizing a straightforward statement regarding the unit’s condition. It also renders enforcement actions in response to false statements impossible. Although not referenced in the Notice, HUD defined life-threatening conditions (for the purposes of executing a HAP contract for a unit with a failed inspection pursuant to HOTMA) in the HOTMA Implementation Notice (82 Fed. Reg. 5458). HUD did not require HAs to use this definition and HAs should continue to use their existing definitions. HAs can add additional requirements to the owner’s certification if desired (such as a certification from the tenant that no life-threatening conditions are present). As soon as possible following the start of tenancy, but no later than October 31, 2020, the HA is to inspect all units according to HQS. Owner certifications can be accepted in lieu of inspections until July 31, 2020.
During tenancy, HAs are required to perform inspections of HCV-assisted units biennially and when complaints are received from government officials or residents. HUD’s waiver allows any inspection due for HCV or PBV units to be delayed to no later than October 31, 2020. For interim inspections (commonly known as “special” or “complaint”), HUD is waiving the inspection requirement, and instead allowing verification of repairs, such as photographs, to be provided to the HA within 24 hours of notification to the owner for life-threatening conditions and 30 days otherwise. There is no requirement for a follow-up inspection to verify repairs were completed. This waiver is also available until July 31.
Unfortunately, several of the waivers effectively backload work for HAs to the end of 2020 or early in 2021.
HUD is also waiving the requirement to conduct inspections for Homeownership program units until July 31, 2020, and quality control inspections until October 31, 2020. For occupied units, the space standards are waived in order to allow additional household members to the assisted unit. Those units will remain in compliance with HQS until the current lease expires but no sooner than April 2021.
HOTMA HQS Provisions (HQS-3 and 4)
- HAs can offer one 30-day extension for NLT repairs
- HAs can delay HQS inspections for units occupied under the alternative inspection option
HOTMA allows HAs to execute a HAP contract and begin assistance payment if the initial inspection fails for only non-life-threatening deficiencies. In these cases the deficiencies must be corrected within 30 days otherwise a payment abatement will begin. HUD is allowing HAs to extend the 30-day repair period by an additional 30 days. HAs may exercise this authority until July 31, 2020. Additionally, if an HA allows occupancy of units with an alternative inspection, HUD is waiving the requirement for an HQS inspection prior to assistance payments are issued to the owner if a certification is provided with the same stipulations as discussed above, including the timeframes.
General HCV Waivers
HUD made ten general waivers available which generally serve two purposes: administrative relief to streamline policy implementation and helping families to find and keep housing.
Administrative Relief (HCV-1, 2, 3, 4, 8, and 9)
All waivers available until July 31, 2020, unless noted:
- The requirement to secure Board approval prior to implementing changes to the administrative plan is waived. HAs must have Board approval for any provisionally adopted changes by that date. HUD has not waived any other regulations pertaining to the administrative plan such as making the plan publicly available and HAs should take care to document any changes to the plan and the effective dates thereof.
- The requirement to provide voucher briefings orally is waived. HAs may implement alternative methods to provide the briefing including through written materials or webinars. HAs can explore recording their briefings and making them available using popular services such as Zoom, Facebook, and YouTube.
- The requirement to extend voucher search periods in accordance with the administrative plan is waived. HAs may want to consider maximizing this waiver by extending all vouchers on the street currently, and those to be issued, until some future date, if local conditions warrant such action. Doing so will decrease administrative burden for the HA and relive pressure from families searching. The supplemental administrative funding en route to HAs should alleviate any concern of the impact of delayed leasing.
- The requirement to execute the HAP contract within 60 days of lease signing is waived. HAs now have 120 days from the lease signed to execute the HAP contract and make payments retroactive to the lease date. HAs should, to the extent possible, prioritize execution of the HAP contract to ensure landlords receive timely payments.
- Although the regulation does not mandate that utility allowance schedules are updated at any point during the year, HUD is notifying HAs that they have until the end of the year to review and update utility schedules.
- The requirement that families attend homeownership and housing counseling prior to receiving assistance under the HCV Homeownership program is waived. HAs that require ongoing counseling should consider amending their local policies.
No additional scores will be issued for SEMAP or PHAS in 2020 unless requested by an HA. All REAC inspections are postponed until further notice except where there is a potential threat to health and safety.
Helping Families to Find and Keep Housing (HCV-5, 6, 7, and 10)
All waivers are available until December 31, 2020:
- The requirement to terminate assistance payments and the HAP contract for units if the tenant is absent for 180 consecutive days is waived. HAs can continue payments through December 2020 at their discretion. HAs that have more restricting limits on family absence from the unit are encouraged to evaluate those policies and amend if appropriate.
- The requirement to automatically terminate HAP contracts 180 days after the last payment is waived. HAs are allowed to defer the termination of the HAP contract until no later than December 31, 2020. This step will preserve assistance for families who temporarily add household members and thus increase household income and provide a safety net for individuals who currently have income but may lose all or some of that income in the coming months. HAs should also remember that terminating the HAP contract automatically terminates the lease and therefore may produce unintended housing instability even for families with stable income.
- The requirement to apply an increased payment standard at the first regular recertification following the effective date of the payment standard increase is waived. HAs can apply the increased payment standard prior to the next regular recertification, including by performing an interim recertification solely for the purpose of applying the new payment standard. This change could decrease the rent burden for families whose total tenant payment exceeds 30 percent of adjusted income.
- The requirement to execute HAP contracts for FUP eligible youth prior to their 25th birthday is waived. HAP contracts for FUP youth can be executed until the youth’s 26th birthday.
Public Housing Program Waivers
HUD has published 10 waivers specific to public housing.
Capital Fund Grant Closeout (PH-1)
Closeout of Capital Fund grants requires HAs to submit an Actual Development Cost Certification within 12 months of the completion or termination of development activity and an Actual Capital Cost Certification within 12 months of the activity’s expenditure deadline. For Capital Fund grants whose deadlines fall between March 1, 2020 and September 30, 2020, this waiver extends both of these deadlines by 6 additional months.
Total Development Costs (PH-2)
For public housing development, mixed finance development and Choice Neighborhoods development, current requirements limit the investment of public housing funds to the sum of Total Development Cost and Housing Construction Cost limits HUD publishes periodically. This waiver allows HAs to exceed those cost limitations by 25 percent without HUD review or approval and request HUD approval of costs between 25 percent and 50 percent above HUD’s published limits. This waiver will remain available for Development Proposals submitted to HUD no later than December 31, 2021.
Costs and Other Limits – Types of Labor (PH-3)
Non-high performing HAs have been able to use force account labor for capital improvements if that use has been included in an HA’s approved Capital Fund Program 5-Year Action Plan. Until December 31, 2020, HUD will waive this restriction and accept the use of force account labor for capital improvements even if the use of force account labor was not included in an approved Capital Fund 5-Year Action Plan.
ACOP – Adoption of Tenant Selection Policies (PH-4)
HUD is waiving the requirement that changes in HAs’ Admission and Continued Occupancy Policies be adopted by HAs’ boards of Commissioners. However, as an alternative requirement, HAs must make sure that such informally adopted policy changes become board approved policies by July 31, 2020.
Community Service and Self-Sufficiency Requirement (PH-5)
HUD will waive the requirement to terminate assistance for noncompliant residents and suspend the 8 hour per month community service requirement for public housing residents until March 31, 2021. HUD’s discussion of this waiver raises questions and PHADA has asked HUD for clarification of this waiver’s impact. The notice indicates:
If a PHA adopts this waiver, tenants will not be subject to this requirement until the family’s next annual reexamination. Upon the family’s next annual reexamination, PHAs should report on Form HUD-50058 each individual’s CSSR status as either exempt… or pending…. After a PHA completes an annual reexamination for any family, the CSSR becomes effective again for family members for the subsequent annual reexamination cycle.
If an agency adopts the waiver effective in April, it will report a family with a May 1 annual reexamination as pending. The waiver will expire on March 31, 2021. On May 1, 2021, what will a family need to do to comply with the reinstated community service requirement? It may need to have completed community service for April 2021, or it may need to have completed the eight hour per month community service requirement since its last reexamination on May 1, 2020.
- Would the family need to “make up” 8 hours of community service (for April 2021) in the subsequent reexamination period,
- Must it “make up” the full year’s community service requirement in its subsequent reexamination period (11 months within the waiver period and 1 month after the waiver’s expiration), or
- Is the family relieved of all community service requirements from May 1, 2020 through May 1, 2021?
A much simpler approach for HUD would have been to waive the requirement until March 31, 2021, and reimpose the requirement on each eligible family going forward at its first reexamination after March 31, 2021. HAs would then begin community service compliance reviews at reexaminations that occur after March 31, 2022.
Energy Audits (PH-6)
HAs must complete energy audits for each of their properties once every 5 years. HUD is waiving the requirement and suspending the deadline for audits that are due in 2020 for one year.
Over Income Families (PH-7)
If a family’s income exceeds 120 percent of the applicable area median income limit (which is 80 percent of AMI) for two consecutive reexamination cycles, an HA must either terminate the family’s assistance or impose an alternative rent based on FMRs or per unit subsidy. If an HA elects to delay annual reexaminations under waiver PH and HCV-2, that delay will effectively suspend enforcement of the over income requirements until families’ next reexaminations consistent with that waiver (some time before December 31, 2020). This waiver does not appear to suspend the overall over income requirements, and so the months during which an HA may suspend the requirement will still count toward a public housing tenant’s 2 year grace period before their assistance is terminated or the basis of their rent changes.
Resident Council Elections (PH-8)
Resident Council members must be elected at least once every 3 years. HUD will waive this requirement through July 31, 2020 but requires that elections be rescheduled as soon after July 31, 2020 as practicable. The notice appears to give HAs and Resident Councils broad discretion to determine when it may become reasonably possible to reschedule those elections.
Utility Allowances (PH-9)
HUD will waive the requirement for HAs to review and revise utility allowances annually and allow HAs to delay those reviews and revisions. However, any review due to be conducted in 2020 must be completed by the end of 2020 along with adoption of any required utility allowance revisions.
Tenant Notifications for Changes to Project Rules and Regulations (PH-10)
HUD will waive its requirement for tenants to receive notice of proposed changes to property rules and regulations 30 days in advance of their adoption except for changes to tenant charges. This waiver expires on July 31, 2020. The notice reminds HAs of the importance of informing impacted residents of such changes within 30 days of their adoption during this waiver period.
Other Waivers and Administrative Relief
SEMAP and PHAS
No additional scores will be issued for SEMAP or PHAS in 2020 unless requested by an HA. All REAC inspections are postponed until further notice except where there is a potential threat to health and safety. HAs will retain their most recent scores. HUD will issue new SEMAP and PHAS scores starting with HAs with FYEs of March 31, 2021. The notice does not describe the data HUD will use to determine PHAS scores after March 31, 2021, and HUD will likely have to provide further waivers as COVID-19 will have significant impacts on HA operations for most of 2020.
Financial Reporting Compliance Dates
Unaudited Financial Information
For HAs with FYEs of December 31, 2019 or March 31, 2020, HUD will extend the deadline for submission of unaudited financial statements for 6 months to August 31, 2020, and November 30, 2020, respectively.
Audited Financial Information
For HAs with FYEs of June 30, 2019, September 30, 2019, December 21, 2019 and March 31, 2020, HUD will extend the deadline for submission of audited financial statements by 6 months to September 30, 2020, December 31, 2020, March 31, 2021, and June 30, 2021, respectively.
HUD is waiving the requirement to submit 50058 information within 60 days of actions’ effective dates; those forms are now due within 90 days of the effective date. The Department also acknowledges that implementation of certain waivers will result in fatal errors in those submissions. The Department will issue future guidance with “workarounds to avoid any potential issues in the PIC system.” For HAs that submit HUD 50058s and receive fatal errors, PIH will not require resubmission and encourages agencies not to resubmit those records until HUD publishes its guidance. For agencies that successfully submit HUD 50058s before publication of supplementary guidance, HUD’s notice announces that the Department may require those agencies submit corrections to those HUD 50058s.
Designated Housing Plans
The Department is waiving its 60-day deadline to review Designated Housing Plans for plans submitted after March 1, 2020 “to ensure that it can review and adequately address any fair housing concerns.” HUD will endeavor to complete those reviews as expeditiously as possible and the waiver currently expires on July 31, 2020. HUD unfortunately did not relax requirements for biennial updates to HAs’ allocation plans and PHADA is requesting this relief.
Obligation and Expenditure Deadlines of Capital Funds
HUD’s discussion of these deadlines cites the Secretary’s authority in existing rules to extend obligation deadlines but not expenditure deadlines although the broad authority granted in the CARES Act would seem to make that standard authority moot. At any rate, HUD is extending the deadlines for both obligation and expenditure of Capital Fund resources, “by one year from the current obligation and expenditure end date.” However, because of statutory restrictions on the availability of appropriations for specific periods, HUD will not extend expenditure deadlines, “beyond one month prior to the closure of the relevant appropriation account.” The notice does not explain HUD’s justification for this limitation. It may affect expenditure deadline extensions for Capital Fund grants made with prior year appropriations. The notice also does not detail impacts of this limitation on expenditure deadline extensions.
HAs should continue to reach out to PHADA with an questions or concerns regarding waivers or other challenges during this time.