Groups Coalesce on Budget and Policy Matters
PHADA President Mark Gillett.
My agency has been a member of PHADA, CLPHA, and NAHRO for many years. Since we are not a Moving to Work agency, Oklahoma City is not a member of the MTW Collaborative, but we have also worked closely with its leadership in recent years.
To be sure, each of the groups brings its unique perspective to federal policy and budget matters. Still, we have much in common and during my presidency, I have stressed the need for mutual collaboration. Considering the existential threats our programs are facing, joint efforts are necessary now more than ever before. I appreciate that the leaders of the other groups feel the same way.
Collaboration Has Increased Since the Pandemic
The industry organizations have always collaborated, but the need for it became necessary about five years ago because of the pandemic. We worked successfully through that period to secure the additional funding and regulatory flexibility we needed to operate during the national emergency.
We know that the regulatory agenda has escalated dramatically since 2020. Since then, there have been new regulations and requirements around HOTMA, HIP, NSPIRE and NSPIRE-V, BABA and others. The four groups have worked jointly to try and make sure the rollout of these requirements is smoother. For example, we secured delays in the implementation of NSPIRE-V and BABA. I know that it has been chaotic but believe we would have faced more difficulties had the groups not worked together.
The organizations were successful on another matter, convincing the Department to abandon its attempt to alter the Annual Contributions Contract in such a way that it would have limited our legal rights. That success was in part based on earlier collaboration in two lawsuits against the federal government and its illegal operating reserves offset. The litigation was a joint effort led by PHADA, NAHRO and more than five hundred individuals HAs around the country.
The Trump Administration and 119th Congress
As of this writing, Congress needs to enact either another short-term Continuing (CR) or some other measure to see us through the September 30 fiscal year end.
Following our recent leadership meeting at PHADA’s January conference, we sent Congress joint correspondence to lay out our specific positions. We are urging Congress to make the critical investments needed to preserve and strengthen our nation’s public and assisted housing infrastructure. We call on appropriators to, at a minimum, maintain the Senate-proposed funding levels to prevent negative impacts on vulnerable households.
Like our efforts on FY 25 funding, the organizations will be developing joint recommendations for the fiscal year that begins on October 1. HUD and our programs are already facing major budget and capacity challenges. Now, funding freezes and more budget cuts with additional HUD staff reductions further threaten the viability of our programs. We will work together to oppose those plans in ‘FY 26.
Other Important Matters
The groups have joined forces to urge Congress to expand and improve the LIHTC program modeled on the Affordable Housing Credit Improvement Act (AHCIA). We are all advocating for this legislation, which expands the number of tax credits available, lowers the bond financing threshold for non-competitive tax credits, and enacts policy changes to make tax credit deals more viable in rural and high-poverty communities.
At the end of 2024, we developed a joint presidential transition paper. The associations sent the paper to career HUD staff as well as members of the Trump transition team. The paper lays out our general goals and objectives for the next couple of years including a major push for more local flexibility and deregulation. This week, the groups will send HUD more specific recommendations on regulations that should be waived or scaled back.
Other issues we raised include the need to address fiscal challenges related to uncollected rents and the need for HUD to modernize and vet its information technology systems before implementing the HOTMA rule. Indeed, just two weeks ago, we sent HUD our latest proposed timeline to further delay HOTMA until its HIP system is operational.
In recent days, the groups co-hosted a webinar for HAs on how to deal with Immigration and Customs Enforcement visits to their properties, and we have consulted one another on all the legal issues around recent federal funding freezes and HUD staff reductions. We are mobilizing with many other organizations in our advocacy in response to these moves because they may severely jeopardize our operations.
We have also worked closely, urging HUD and Congress to recognize the dramatic increase in insurance costs. Similarly, we have raised objections and offered suggestions to minimize the impact of HUD’s ill-advised plan to recapture some of our interest income. Also, to help educate our members, the PHADA staff have appeared with other groups in some conference forums around the country.
For the Future
To address long term needs, the groups are working together on the 10-year road map that CLPHA has led to address the viability of affordable housing stock. At the same time, we all continue to support ways to make Rental Assistance Demonstration (RAD) rents more workable.
Finally, PHADA is advocating that the other groups join us in pursuing our Local Flexibility Option, which is modeled on the success and flexibility in the original Moving to Work Program. We believe this kind of flexibility will be even more necessary considering the tight budgets we expect for the foreseeable future. We also believe local flexibility can result in improved outcomes for residents, as demonstrated through MTW, RAD and implementation of CARES Act waivers during the pandemic.