Housing Choice Voucher Program CY 2019 Implementation

Housing Choice Voucher Program CY 2019 Implementation

Housing Choice Voucher Program CY 2019 Funding Implementation Webcast Public Housing Agency Briefing April 2019 1 Todays Topics CY 2019 Voucher Renewal Funding CY 2019 HAP Set-Aside CY 2019 Administrative Fees Other Voucher Funding

HCVP Financial Management 2 FFY 2019 Appropriations HUD operated under a continuing resolution prior to enactment of FFY 2019 Appropriations, allotments were received based on FFY 2018 appropriations during the CR period January through May 2019 obligations to PHAs have been made based on that level of funding and individual PHA CY 2018 estimated renewal eligibility amount; disbursements based on projected need Public Law 116-6 was enacted February 15, 2019, providing full year appropriations

HCVP portion included in 2019 implementation 3 notice FFY 2019 Appropriations HAP Renewal Funding Tenant Protection Vouchers Administrative Fees Mainstream Program Tribal HUD-VASH Renewals Veterans Affairs Supportive Housing Family Unification Program Mobility Demonstration Total $20,313,000,000 $85,000,000 $1,886,000,000 $225,000,000 $4,000,000 $40,000,000

$20,000,000 $25,000,000 $22,598,000,000 4 Voucher Renewal Funding Increase of $713,000,000 from the 2018 Renewal appropriations HUD may use up to $100,000,000 of CY 2019 Renewal Funding as a HAP Set-Aside 5 Voucher Renewal Funding PHA renewal allocations are calculated per the Appropriations Act, summarized as follows: (1) Re-benchmarking conducted, based on actual

HAP costs for CY 2018, per VMS reporting and HUD review, not to exceed costs for baseline units (2) Initial funding is inflated per renewal inflation factors for new increments that span 2018 and 2019 (3) Renewal Inflation Factor applied 6 Voucher Renewal Funding PHA renewal allocations are calculated per Appropriations Act: (4) The National Pro-ration Factor is set at 99.5% (5) A small offset was necessary to increase the

pro-ration to 99.5% and to prevent the termination of renewal assistance for families Result is CY 2019 Prorated Renewal Funding Remember: PHAs may also have non-renewal funding and RNP/Program Reserves available to support CY 2019 HAP needs 7 Voucher Renewal Funding PHAs pro-rated eligibility is compared to renewal funds obligated January through May 2019 If HAP obligations through May 2019 are less than pro-rated eligibility after offset (if there is any offset), the difference will be obligated

Otherwise, if obligations exceed pro-rated eligibility after offset (if there is any offset), the excess will be reduced from subsequent obligations throughout the year 8 Voucher Renewal Funding (1) Re-benchmarking Based on submitted and validated CY 2018 HAP costs per VMS, as of February 22 deadline HAP costs capped at 100% of baseline vouchers to ensure over-leasing is not funded: UMAs divided by UMLs, not to exceed 100%

Example: 1000 UMAs / 1050 UMLs = .95238 HAP costs = $1,000,000; multiplied by .95238 to yield baseline eligibility of $952,380 = amount to renew 1000 UMAs 9 Voucher Renewal Funding (2) Adjustment for first time renewals Applies to new (not renewal) increments effective after January 1, 2018 An inflation adjustment per the renewal inflation factor is applied for the months in CY 2019 (3) Renewal Funding Inflation Factor is applied to the PHAs calculated 12-month renewal requirement after

adjustments for steps 1 and 2 have been applied (4) Proration: HUD determines a total eligibility for all PHAs and compares that amount to the total available HAP renewal funding per the 2019 Act in order to determine a proration factor (proration is 99.5%) 10 Voucher Renewal Funding (5) Appropriations Act again authorizes HUD to offset excess funds (RNP and program reserves) in order to: Avoid or reduce the need for proration of renewal funding; and Prevent termination of assistance as the result of insufficient funding The Department is exercising offset authority

in CY 2019 to increase pro-ration level to 99.5% and to prevent the termination of assistance of families due to insufficient funding 11 Offset for Reallocation The December 31, 2018 reconciled HAP program reserves Protect from offset the following amounts to the extent reserves are available to protect: Difference between PHAs eligibility and prorated eligibility CY 2019 amounts needed to fully fund the leasing of VASH units

Difference between the higher of December 2018 UMLs x 12 or CY 2018 UMLs up to baseline units under ACC December UMLs (Capped) CY 2018 new incremental BA (1/2 of award) CY 2018 Set-aside protection (1/2 of award) Portion of 2019 renewal eligibility (based on units 12 under ACC): 4% - 501 and above units

Offset for Reallocation PHAs with CY 2018 Inflation factors that were higher than the CY 2018 national weighted average inflator Result is total available for offset Offset amount (total available for offset = 52% of available and unprotected reserves) Note: PHAs that were determined to be a shortfall PHA in CY 2018 are exempt from offs. Disaster impacted PHAs that applied and were awarded13 disaster HAP Set-aside funding are also exempt Renewal Disbursements

For CY 2019: Disbursements are based on cash management requirements per PIH Notice 2017-06 Margin will vary based on national leasing and cost fluctuations Margin does not change funding eligibility PHAs must still assess level of program they can support across the CY based on total HAP funding and RNP/HUDheld reserves available, actual expenses to date, and projected expenses 14 Renewal Disbursements For CY 2019:

Frontloads will continue to be available, up to the total budget authority obligated for the PHA and available HAP reserves Non-renewal disbursements will continue to be made based on contract terms of incremental awards and/or Notice of Funding Availability (NOFA) (tenant protection, VASH, Mainstream, FUP and RAD) Total HAP disbursements will be reconciled against total HAP expenses twice annually 15 Voucher Set-Aside Funding

Up to $100,000,000 of renewal appropriations may be used to augment renewal allocations for the following purposes: Prevention of terminations due to insufficient funding Unforeseen circumstances Portability cost increases Project-Based Vouchers HUD-VASH If there are any funds remaining after all categories are funded, these funds will be

distributed to all PHAs on a prorated basis 16 Voucher Set-Aside Funding Prevention of terminations due to insufficient funding Scenario 1 PHAs already in shortfall At the time of set-aside application, PHA is working with HUDs Shortfall Prevention Team and SPT has confirmed the PHA is in shortfall PHA has ceased issuing vouchers as of the date of notification by the SPT of a potential shortfall; however, this is subject to the following exceptions: participants issued vouchers to move;

up to the VASH total UMAs (VASH units under ACC for the CY), including turnover; vouchers issued under special-purpose increments awarded in CY 2018 or CY 2019 to include VASH, FUP, 17 NED and TP; Voucher Set-Aside Funding Scenario 1 PHAs already in shortfall Exceptions continued: PHAs may enter into project-based HAP contracts for units already under AHAP and may fill vacant PB units

Vouchers issued pursuant to the settlement of litigation (Litigation Vouchers) against a PHA. PHAs must request approval to continue leasing these. All Requests will be reviewed by HUD on a case-by-case basis. Scenario 2 PHAs who managed their program budgets in a responsible manner but later in the year SPT determined to be in shortfall PHA must submit signed CY 2019 Set-Aside Appendix D for either scenario 18 Voucher Set-Aside Funding Shortfalls: Determination of Funding Required

Calculated by HUD using Two Year Projection Tool Compares all resources available to PHA to HAP expenses projected for the year Resources: RNP; HUD-held reserves; CY 2019 renewal BA; CY 2019 portion of incremental BA; set-aside funds Expenses: Current leasing and expense data projected through the year; suspension of vouchers; projected attrition based on prior actual attrition 19 Voucher Set-Aside Funding Shortfalls:

PHA anticipating a shortfall should immediately contact the field office Application period remains open throughout CY 2019; however, PHAs facing shortfalls in October and November 2019, must submit applications no later than 5 p.m. EST, Friday, August 23, 2019, so HUD can provide the funds prior to FFY 2019 close-out For SPT confirmed shortfalls for the month of December 2019, PHAs must submit applications no later than 5 p.m. EST, Friday, November 8, 2019 (HUD reserves the right to accept additional applications on a case-by-case basis after this date) Shortfall funds will be awarded in the amount needed for 20 the PHA to end CY 2019 with $0 RNP and reserves Voucher Set-Aside Funding

Unforeseen Circumstances Eligibility: Unforeseen circumstance is an occurrence within or after the re-benchmarking period, which the PHA could not reasonably have known in advance and was out of the PHAs control Submission Requirements: Signed 2019 Appendix E; Detail Narrative of the unforeseen circumstances occurred during or after the CY 2018 re-benchmarking period that have significantly increased renewal costs; Evidence to support the narrative; and

PHAs calculation of the increased costs for CY 2019 21 Voucher Set-Aside Funding Portability - Eligibility: PHA must have experienced a significant increase in renewal costs due to portability (HUD will calculate) Portability average HAP PUC for re-benchmarking period must exceed program-wide PUC by 10% Eligibility will be HAP difference multiplied by the unit months leased for Port Vouchers Paid Submission Requirements: Signed Set-Aside Appendix E for CY 2019

22 Voucher Set-Aside Funding Project-Based Vouchers Eligibility: Vouchers were not in use during the rebenchmarking period, in order to be available to meet a commitment for PB vouchers assistance Adjustment will not exceed the number of unleased unit months Only new construction and rehabilitated housing are eligible 23 Voucher Set-Aside Funding

Project-Based Vouchers Eligibility: Submission requirements: Specific sections of the executed AHAP agreement (see the Notice) If executed, specific sections of the HAP agreement (see the Notice) Signed Set-Aside Appendix E for CY 2019 Signed Set-Aside Appendix F and G for each project requested 24

Voucher Set-Aside Funding HUD-VASH - Eligibility: Per Unit Cost Increase: Program-wide funded CY 2019 HAP PUC is less than current VASH HAP PUC Leasing Increase: Total VASH leasing for CY 2019 will exceed the level included in renewal funding plus leasing that will be supported by RNP and reserves HUD will calculate eligibility; no documentation required HUD will calculate eligibility; no documentation required Submit signed CY 2019 Set-Aside Appendix E 25

Voucher Set-Aside Funding Mailing Address for Shortfall Set-Aside Requests: U.S. Dept. of Housing & Urban Development Office of Housing Voucher Programs Attn: Miguel Fontanez, Director FMD 451 7th St. SW., Room 4226 Washington, DC 20410 Electronic Address for Set-Aside Requests: [email protected] Subject Line: PHA Number, 2019 Set-Aside Application Applications must be received by 5 p.m. EDST,

on May 31, 2019 26 Administrative Fees CY 2019 Admin Fee Funding: $1,886,000,000 HUD MAY use up to $30,000,000 of CY 2019 Admin Fee funding as a set-aside for housing conversion special fees, fees for portability and homeownership, etc. 27 Administrative Fees Admin fee funds are advanced monthly, based on latest reconciled eligibility Admin fees are reconciled quarterly; for CY 2019 earnings are anticipated to equal

approximately 79% of eligibility PHAs must take actions to reduce costs if fees and UNP (formerly know as UNA) are insufficient PIH Notice 2012-15 discusses streamlining administrative practices to reduce costs HAP funds may not be used for admin costs 28 Administrative Fees CY 2019 AF schedules is posted on the HCV website: https://www.hud.gov/program_offices/public_india n_housing/programs/hcv

Rates are retroactively effective January 1, 2019 PHA requests for higher admin fees rates must be received by HUD by Friday, May 31, 2019. Requests are submitted to Financial Management Center. Blended fee requests are submitted to Financial Management Division; no supporting data needed. The application deadline is Friday, May 29 31, 2019 Administrative Fees

Special Fees/Set-Aside: Homeownership (HO): $200 for every HO closing reported in PIC for HCV families who have become homeowners through the HCV Homeownership program, MTW Homeownership program and FSS program (HCV only) HUD will also fund a one-time $500 special fee for each newly created Homeownership Program at any PHA in CY 2019 HUD will calculate and disburse, based on PIC reporting - no PHA application required 30 Administrative Fees

Special Fees/Set-Aside: MF Housing Conversions: $200 for each unit occupied on the date of the eligibility event HUD will calculate no separate PHA application required for fees Special Portability Fees: PHAs administering port-in vouchers which equal 20% or more of the PHAs total leased vouchers as of December 31, 2018

Funding: 15% of PHAs Column A fee rate for each eligible port-in voucher for 12 months HUD will calculate and disburse, based on portability data 31 in PIC and leased data from VMS; no PHA application required Administrative Fees Special Fees/Set-Aside: Special Fees for audit costs for declaring major HCV programs per PIH Notice 2015-16 and for HCV voluntary transfers per PIH Notice 2018-12 All special fees Needed for Administration of Section 8 Tenant-Based Rental Assistance Program:

PHAs experiencing increased administrative expenses, including as a result of administration of tenant protection rental assistance, disaster related vouchers, HUD-VASH vouchers, and other special purpose incremental vouchers can request special fees separate guidance for submitting special fee requests will be provided to PHAs via email notification at a later date, to include deadlines for submissions The Department reserves the right to fund one, some, or all the categories 32 Tenant Protection Vouchers $85,000,000 appropriated

TPVs are provided to protect HUD-assisted families from hardship as the result of a variety of actions that occur in HUDs Public Housing (Low-Rent) and Multifamily Housing portfolios In many cases TPVs mitigate the loss of HUD-assisted housing units in the community because these TPVs become part of the PHAs HCV program and may be reissued to families on the PHAs waiting list upon turnover. For additional programmatic and policy guidance related to TPVs, please refer to Section 6 of the 2018 Implementation Notice, PIH Notice 2018-09, Implementation of the Federal Fiscal Year (FFY) 2018 Funding Provisions for the Housing Choice Voucher 33 Program. Tenant Protection Vouchers

NEW POLICY - Vacant Units In addition to providing replacement vouchers for occupied units, per PIH Notice 2018-09, HUD will also provide replacement TPVs for vacant units that were occupied within the previous 24 months. The examples below explain how this policy will work: For Public Housing actions - vacant units occupied within the previous 24 months from the time of the SAC or Choice Neighborhoods Initiative approval. Example: on February 1, 2019, PHA A was approved for demolition/disposition of 25 public housing units. 5 of those units were last occupied on February 1, 2017. Remaining units continue to be occupied. Replacement TPV funding may be provided for all 25 units (vacant and occupied) because the 5 vacant units were last occupied less than 24 months from the SAC approval. For Multifamily Housing actions vacant units occupied within the previous 24 months from the eligibility event. Example: on February 1, 2019, the prepayment of a section 236 mortgage in property A triggered eligibility for TPVs. Of 25 units in property A, 5 were last

occupied on February 1, 2017. The remainder of the units continue to be occupied. Replacement TPV funding may be provided for all 25 units (vacant and occupied) because the 5 vacant units were last occupied less than 24 months from the eligibility event. 34 VASH Funding Veterans Affairs Supportive Housing $40,000,000 Awarded based on geographic need HUD will issue comprehensive guidance for this competition at a later date 35 Tribal HUD-VASH Renewals

The 2019 Act provides $4,000,000 for rental assistance and associated admin fees to serve Native American Veterans that are homeless or at-risk of homelessness living on or near a reservation or other Indian areas Any amounts remaining after renewals may be used for new grants under this program For further guidance from the Office of Native American Programs will be provided at a later date 36 Mainstream Program The 2019 Act provides $225,000,000 for Mainstream

Mainstream voucher renewals will be based on validated Mainstream Program leasing and HAP expenses as reported in VMS for CY 2018, in the same manner as other vouchers, but in a separate renewal action Administrative fees will be based on leasing as of the first of each month and will be prorated at the same level as fees for other vouchers The 2019 Act also provides that any funds remaining available after funding renewals and administrative expenses shall be available for incremental tenant-based assistance. 37 HUD plan to award a portion of the funding made

Family Unification Program (FUP) The 2019 Act provides $20,000,000 for new incremental FUP The 2019 Act also provides that any PHA administering voucher assistance appropriated in a prior Act under FUP that determine that it no longer has an identified need for such assistance upon turn-over, shall notify the Secretary, and the Secretary shall recapture such assistance from the agency and reallocate it to any other PHA(s) based on need for FUP voucher assistance HUD will implement this provision through guidance in a NOFA that will be provided at a later date. 38

Mobility Demonstration The 2019 Act provides $25,000,000 for a mobility demonstration. The purpose of the demonstration is to enable PHAs to administer HCV assistance in a manner designed to encourage families with children to move to lower poverty areas and expand access to opportunity areas. The Department will publish a separate Federal Register notice to implement the mobility demonstration and announce the competition for funding. 39 HCVP Financial Management

PHAs must manage their programs in a responsible manner to enable them to serve families within their CY 2019 allocations, RNP and reserves, and within voucher baselines PIH Notice 2011-28 provides guidance on costsavings measures PHAs may take to reduce financial shortfalls in the HCV program PIH Notice 2013-28 stipulates that PHAs may not use outside funding sources to maintain or increase leasing, but only to prevent terminations; prior HUD approval required to use outside funding and to report in VMS the expenses it supports 40 HCVP Financial Management PHAs are encouraged to lease as close as possible to their capacity, without incurring a shortfall or exceeding the PHAs baseline

PHAs should use the Two-Year Tool and update it regularly to see the vouchers that can be supported in the current year and the next year 41 Questions? Any questions may be submitted to [email protected] 42

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