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HUD Issues Important Update to Frequently Asked Questions for Public Housing Agencies

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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