WI Public Housing

Public Housing UpdatesWAHA Fall Conference

September 16, 2015

John Finger, Program Center CoordinatorAnne Steffel, Financial Analyst

DeAnna Alfonso, Construction AnalystScott Koegler, Portfolio Management Specialist

WI Public Housing

THANK YOU!WI PHAs continue to do a great job of

administering your programs in a difficult financial and regulated environment.

All field office staff appreciate the continued dedication and efforts to provide affordable

housing in WI.

2

WI Public Housing 3

General Occupancy• Please note that ALL PHAs are now

designated as General Occupancy. • See Announcement WI PIH 2015-1, emailed to all PHAs on

3/9/2015 from John Finger• WI PIH 2015-1 describes in detail the statutory and regulatory

background for the implementation of the general occupancy eligibility.

• PHA may implement local preferences in their ACOP as detailed at 24 CFR part 960.206

WI Public Housing

PH Occupancy

4

WI Public Housing

PH Community Service & Self Sufficiency CSSR

• Quality Housing & Work Responsibility Act of 1998 (QHWRA)

• OIG Audit of CSSR released February 13, 2015• Notice PIH 2015-12 issued August 13, 2015• 24 CFR 960.600 through 960.609• HUD will be monitoring CSSR reporting on the

HUD-50058s quarterly

5

WI Public Housing

Public Housing CSSR

• Requires performing 8 hours of community service or economic self-sufficiency for every month residency

• May be 8 hours each month or aggregated across a year – As long as total 96 per year

• Examples of Eligible Community Service & Self-Sufficiency Activities in PIH 2015-12

6

WI Public Housing

PH Community Service & Self Sufficiency

• PHAs must adopt a local policy for CSSR to be included in your ACOP

• ACOP must describe process to determine exemption from CSSR Requirements

• Must provide family copy of CSSR at initial application w/ certification of receipt

• Family must sign CSSR certification at re-examination

7

WI Public Housing

Exemptions from CSSR• PIH Notice 2015-12 has examples • Engaged in Work Activities

– HUD encourages 30 hours per week standard • 62 years or older• Blind or disabled as defined by 216(i)(1) or

1614 of Social Security Act• Receiving and in Compliance with State

Welfare Program benefits– SNAP– Welfare to Work

8

WI Public Housing

Reporting CSSR

• PIH 2015-12 has guidance on 50058 Coding• OIG Audit noted significant number of

reporting errors for CSSR• HUD will send quarterly reports with potential

CSSR reporting issues • PHAs may correct information on next annual

re-examination or interim re-exam

9

WI Public Housing 10

PH Community Service Requirement

• The lease must contain a clause stating that PHA may not renew the lease if the family has violated the requirements to perform community service or economic self-sufficiency activities (24 CFR Part 966.4 (2)(ii)). WAHA has developed a community service and self-sufficiency policy that may be used.

WI Public Housing

Homeless at Admission Reporting

• Must determine whether family was homeless for ALL new admissions

• Must be reported at question 4c on HUD Form 50058

• Definition of homeless found in PIH Notice 2013-15

• PHA may adopt narrower definition for waiting list preference but must still use 2013-15 definition for question 4c

11

WI Public Housing 12

ACOP Update• Many Wisconsin Admissions and Continued Occupancy Policy

(ACOP) documents are out of date. They should not be over five years old.

• Please note that once the ACOP and lease are updated your tenants must be given a 30 day written notice to review and provide comments as required by 24 CFR part 966.5 Posting of policies, rules and regulations.

• A copy of such notice shall be: – (a) Delivered directly or mailed to each tenant; or – (b) Posted in at least three (3) conspicuous places within each

structure or building in which the affected dwelling units are located, as well as in a conspicuous place at the project office, if any, of if none, a similar central business location within the project.

WI Public Housing 13

ACOP

• The ACOP must include guidance from the following PIH Notices:– 2015-02 Administrative Guidance for Effective and Mandated Use of

the Enterprise Income Verification System, which extends PIH Notice 2010-19 indefinitely.

– 2014-20 Program Eligibility Regardless of Sexual Orientation, Gender Identity, or Marital Status as required by HUD’s Equal Access Rule

– 2014-12 Changes to Flat Rent Requirements– 2012-34 Waiting List Administration– 2012-29 Establishing the Passbook Savings Rate

WI Public Housing 14

Lease Update

• HUD LEASE requirements – See 24 CFR § 966.4• Section contains specific Tenant Notification Requirements.• The lease must contain the provisions of Quality Housing and Work

Responsibility Act of 1998. • The lease must state that additions to a tenant household other than

births, adoption, or court-awarded custody require the family to request PHA permission prior to permitting anyone not listed on the lease to occupy the unit (24 CFR Part 966.4 (a)(v)).

• The lease term must be one year, renewable for subsequent one year terms (many PHAs had month-to-month leases or month-to-month renewals) (24 CFR Part 966.4 (2)(i)).

• UPDATE your leases – Contact the FO for further advice.

WI Public Housing

2016 Op Sub Update

• Nothing currently on website, but there are some pre-checks that PHA’s should do prior to start of 2016 Op Sub.

• The Public Housing Financial Management Division (HUD) will be pre-populating Operating Subsidy Tools (HUD-52722 and HUD-52723 tools) based directly on PIC data.

• Two areas to check : – Unit count detail – compare PIC data to PHA monthly totals.– Utility consumption and expense totals to determine if information is

suspect

15

WI Public Housing

2016 Op Sub Update (cont.)• Powerpoint presentation on PIC unit data detail report – step by

step instructions on how to download PIC data.

• PIC Unit Data report will provide information on what currently is entered in PIC. Available in PIC system.

• Compare monthly totals to PHA monthly counts.

• If different, run detail summary report for month in question to determine unit that is incorrectly coded.

• Utility Compensation / Expense worksheet – looks for variations from one month to the next to identify potential problems.

16

WI Public Housing

Flat Rents– PIH Notice 2015-13: Changes to Flat Rent Requirements – FY

2015 Appropriations Act

– Previous provisions apply, i.e. flat rents must be no less than 80% of published FMR

– 2015 further amends to allow options:• Applicable published FMRs

• At the discretion of the Secretary, such other applicable fair market rental established by the Secretary that the Secretary determines more accurately reflects local market conditions and is based on an applicable market area that is geographically smaller than the applicable market area

• PHAs may also use the applicable Small Area Fair Market Rent (SAFMR), which HUD will publish annually.

17

WI Public Housing

Flat Rents– PHAs may apply for a waiver to options (Exception Flat rents)

• PHAs may request an exception flat rent that is lower than either 80 percent of the lower of the FMR or SAFMR/unadjusted rent if the PHA can demonstrate that these FMRs do not reflect the market value of a particular property or unit.

• PHAs must submit a market analysis methodology that demonstrates the value for the unit.

– HUD does not prescribe a particular formula for determining the market analysis, but it must compare the PH unit to unassisted units in the area using the following factors:

• Location, quality, size, unit type, age of the unit, and

• Amenities, housing services, maintenance, and utilities the PHA will provide under the lease.

18

WI Public Housing

Section 3 Reporting System

– FHEO is re-launching the Section 3 Performance Evaluation and Registry System (SPEARS) for the submission of Section 3 annual summary reports (Form HUD 60002).

– All submissions of 2013 and 2014 Section 3 summary reports must be submitted electronically no later than October 30, 2015. Paper copies will not be accepted.

– Please direct technical assistance questions for accessing SPEARS through WASS to HUD’s REAC Technical Assistance Center at (888) 245-4860.

19

WI Public Housing

Section 3 Reporting System

– All other questions or concerns about Section 3 reporting requirements should be sent to 60002questions@hud.gov.

– To access SPEARS all users, including PHAs, must have an active WASS account as a Multifamily Business Partner—even if your agency is not a Multifamily entity. Users must also be granted access to the SPEARS system by an authorized SPEARS coordinator from your agency.

– User Registration Instructions, HUD 60002 Form Instructions, a HUD 60002 Form Quick Guide, Frequently Asked Questions (FAQs), and a YouTube training video that demonstrates steps to be taken to complete and submit the HUD 60002 Form are posted at: www.hud.gov/Section3.

20

WI Public Housing

Lead the Way Training• Training Modules available on HUD Exchange• FREE Self-paced internet based training• Addresses 6 Key Aspects of PHAs• Developed as training for PHA boards – but

can be beneficial to all involved with PHAs

21

WI Public Housing

HUD Resource Locator

• Available on Desktop, Tablet and mobile platforms

22

WI Public Housing 23