Additional Waiver Information Coming Soon
David Weber, PHADA Policy Analyst
On Monday, March 30, HUD released an updated COVID-19 Frequently Asked Questions (FAQs) document on their website. It can be accessed here.
While many important questions regarding waivers are deferred until a formal waiver notice is issued, many questions are clearly answered in this document. Highlights include the following:
- Procurement Regulations at 2 CFR 200.320(f) allows single source procurement in specific circumstances, including “A public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation.” Remember to document the file appropriately and comply with any more stringent state or local requirements.
- PHAs can adopt a variety of HQS flexibilities under current rules, although additional waivers may be forthcoming. These include biennial inspections and acceptance of alternative inspections for periodic inspections (both PIH 2016-05); accept alternate validation of deficiency corrections (photo rather than reinspection, for example); and the HOTMA Non-Life threatening provision (PIH 2017-20) or HOTMA Alternative Inspection provision allowing move-in and HAP execution without a passing HQS inspection. Additional guidance and possible waivers on inspections are forthcoming.
- Stimulus payments to individuals will be excluded from income.
- HUD intends to extend Capital Fund Obligation and Expenditure deadlines for all open Capital Fund grants for one year.
- Consistent with OMB guidance, HUD is extending due dates for all audited financial statements by six months.
- Agencies with FYE of Dec. 31, 2019, or Mar. 31, 2020, are also being granted a six-month extension on submission of unaudited financial statements.
- HUD is suspending issuance of quarterly EIV discrepancy letters for the second quarter and will determine at a future date when to reinstate the discrepancy letters.
- HUD Mainstream Voucher program awardees will have an additional six months to achieve lease-up goals.
- In-person meetings are not required in the regulations, and PHAs can use alternate methods to collect information. If third party verification of income or a change of income is not available, document the attempt to verify “and continue with the process to adjust the tenant payment.”
- HUD asks agencies not to submit waiver requests until the formal Waiver Notice is issued.
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