Requests PHAS Scoring Changes for TARs, Reconsideration of the 30-Day Notice Requirement
In response to members concerns raised during PHADA‘s 2023 Legislative Forum, September 17–19 in Washington, DC, PHADA has written to Secretary Fudge repeating and emphasizing concerns about the growing threat to HA programs posed by increased Tenant Accounts Receivables (TARs), and how the 30-day notice requirement negatively impacts both HAs and tenants in those jurisdictions.
- HUD identified 20% of HAs as “severely impacted” by TARs in 2019–2020.
- TARs rates continue at twice the rate of pre-pandemic numbers.
- Public Housing Operating Fund Shortfall funding eligibility was more than 10 times higher than the appropriated amounts.
- Tenant rent makes up 50% or more of a public housing program’s operating revenue, so TARs above the assumed (low) level of the Operating Fund Formula are a serious threat to agencies‘ cash flow and financial positions.
- The austerity measures that are needed in such situations reduce the quality of housing maintenance and management, extend unit turnaround times, and have other negative impacts on agencies and residents.
- It is not clear that requiring a 30-day notice for non-payment of rent actually reduces evictions when emergency assistance is not available.
- Increased notice periods often lead to higher owing balances and the resulting short and long-term negative impacts on households.
The Letter Requests:
- HUD should modify PHAS for TARs-related measures to prevent any negative scoring as a result of factors beyond the agency’s control.
- HUD should provide additional data on TARs and their impact on HAs‘ financial position.
- HUD should revisit and reconsider the legal and programmatic considerations relating to the 30-day notice requirement.
Read the full letter with attachments here.