Performance Improvement For the Housing Industry
May 18, 2012 Leave a comment
HUD: Countdown to Father’s Day 2012
NLIHC: Why you should care about the American Community Survey, and what you can do
The White House: Asian American and Pacific Islander Heritage Month
Leave your links and recommendations in the comments.
May 17, 2012 Leave a comment
Tip #2: Develop a method to track EID, even when a family experiences changes in employment.
HUD has noted during RIM reviews and in their Policy Development and Research report that the complexity of the EID regulations often leads to rent calculation errors, most particularly in the process of tracking the two exclusion periods.
The regulations require that qualifying EID family members receive only twelve cumulative months of the initial exclusion, and twelve cumulative months of the phase-in period, over a four-year span. Inconsistency in tracking often leads PHAs to incorrectly extend both exclusion periods beyond these regulatory timeframes.
Tracking becomes even more complicated when multiple family members qualify for the disallowance. Therefore, it’s important for your agency to have a consistent tracking methodology in place. It’s particularly important in the public housing program, because all adult family members can potentially qualify for the EID.
HUD hasn’t developed a standardized tracking system for PHA use. We recommend that agencies either purchase or develop a user-friendly tracking system for staff. Some rent calculation software has the capability of tracking the exclusion over time, and some agencies develop spreadsheets, calendars, timelines, or other tracking forms.
A common strategy is setting automated reminders on responsible staff members’ computers to alert them when it’s time to begin the phase-in or end the exclusion. Another effective tool is having a supervisor maintain a master list of which families qualify for the EID, so that case workers are reminded of the phase-in and end dates of family members’ exclusions.
Becky Gligo has been a trainer and consultant at Nan McKay and Associates since 2008. She trains hundreds of housing authority staff each year, both in open enrollment and onsite trainings. Ms. Gligo recently co-developed a new NMA class, Rent Calc II: Hands-On Workshop, which helps students achieve advanced rent calculation skills through practical hands-on activities.
NMA also offers an Earned Income Disallowance Kit on CD. The kit provides staff with simplified methods to accurately qualify families, calculate the exclusion amount correctly, and track throughout the up-to-48-month qualifying period. Easy computer installation allows staff to view instructions on their computer screens or print for reference.
May 11, 2012 Leave a comment
HUD’s Office of Public and Indian Housing (PIH) has issued a new notice revising its guidance on the financial reporting requirements for the housing choice voucher program through the Financial Assessment Subsystem for public housing and the Voucher Management System.
Notice PIH 2012-21, issued May 10, 2012, replaces previous guidance on the same subject provided in Notice PIH 2010-45 and remains in effect until amended, superseded, or rescinded.
The new notice makes many key changes to the previous guidance. For example:
HUD will not entertain any waivers of the requirement to file FASS-PH reports; however, PHAs that need extra time to make their submissions may request from HUD an extension of the reporting requirement to submit unaudited financial statements or a waiver of the reporting compliance date requirement found at 24 CFR 5.801(d) for submission of audited statements.
NMA’s HCV Financial Accounting and Reporting provides comprehensive training and guidance with the most current HUD rules and regulations. To stay updated on the latest program information, subscribe to the PIH Alert and Housing Resource Newsletter.
May 11, 2012 Leave a comment
Center on Budget and Policy Priorities: Republicans in the House inexplicably voted this week to defund the American Community Survey (ACS), the nation’s main source of state and local data on affordable housing
EPA: Bed bug information clearinghouse launches
HUD: Notice PIH 2012-21 updates guidance on financial reporting requirements
Multi-Housing News: Housing discrimination is still a major problem in the United States for the disabled, immigrants and families with children, among others
Leave your links and recommendations in the comments.
May 9, 2012 Leave a comment
Tip #1: Apply a consistent method when annualizing income.
Inconsistency in the annualization process is one of the most common but avoidable errors found by HUD during file reviews. Does your staff understand, and consistently apply, your agency’s methodology for annualizing income?
Confusion between semimonthly and biweekly income is one of the most common mistakes. Semimonthly means twice a month; biweekly means every two weeks.
When calculating income from the wages of a family member who is generally paid twice per month, it’s important to establish whether they’re paid semimonthly or biweekly.
For example, while someone who is paid every other Friday (biweekly) will typically receive two paychecks per month, twice a year the individual will actually receive three paychecks per month. If your staff assumes that this individual’s wages are semimonthly, and that they’re paid a total of 24 times per year, you’ll be omitting two weeks of pay, thereby causing a PHA overpayment.
To prevent confusion, it’s important to follow PHA policy on the number of pay stubs required to make accurate income determinations. Once those pay stubs are collected, staff should critically examine the pay periods they show.
Another common error occurs when family members are seasonally employed and pay is inconsistent throughout the year. The definition of annual income requires PHAs to project income for the upcoming twelve-month period.
When a family member is not consistently employed over that period, your agency’s policy must address what methodology staff is to use. This can mean either conducting interim reexaminations as wages change, or carefully projecting income using all known sources.
The Housing Choice Voucher Guidebook provides the following example of seasonal employment:
Calculating anticipated annual income
A teacher’s assistant works nine months annually and receives $1300 per month. During the summer recess, the teacher’s assistant works for the Parks and Recreation Department, earning $600 per month. The PHA may calculate the family’s income using either of the two following methods:
- Calculate annual income based on current income: $15,600 ($1300 x 12 months). An interim reexamination would then be conducted at the end of the school year to recalculate the family’s income during the summer months at the reduced annualized amount of $7200 ($600 x 12 months).
- Calculate annual income based on average experience: $11,700 ($1300 x 9 months) + $1,800 ($600 x 3 months) = $13,500. Using this second method, an interim reexamination would not be conducted at the end of the school year. In order to use this method effectively, some history of income from all sources in prior years should be available.
Regardless of which methodology PHA staff employs, the key to successful annualization lies in projecting income over a twelve-month period. We recommend that agencies have consistent and well-communicated annualization policies and procedures to ensure accuracy in all rent calculations.
Becky Gligo has been a trainer and consultant at Nan McKay and Associates since 2008. She trains hundreds of housing authority staff each year, both in open enrollment and onsite trainings. Ms. Gligo recently co-developed a new NMA class, Rent Calc II: Hands-On Workshop, which helps students achieve advanced rent calculation skills through practical hands-on activities.
May 4, 2012 Leave a comment
CLPHA: Comments to HUD on Rental Assistance Demonstration (RAD)
Habitat for Humanity (via GoSection8): Studies indicate conclusively that affordable housing has little or no effect on neighboring property values
HUD: $56 million in grants to promote affordable housing in Native American communities
Multihousing News: Finding energy incentive programs
NAHRO (requires a login to view): Comments to HUD on Rental Assistance Demonstration (RAD)
NCSHA: Comments to HUD on Rental Assistance Demonstration (RAD)
New America Media (via Affordable Housing Report): Affordable housing wobbles as redevelopment agencies close
NLIHC: Advocates agree that HUD has a very meaningful impact
PD&R Edge: HUD’s Rental Assistance Demonstration (From the Assistant Secretary)
PHADA (requires a login to view): Comments to HUD on Rental Assistance Demonstration (RAD)
Leave your links and recommendations in the comments.
May 3, 2012 Leave a comment
Last week NMA hosted an “Ask the Experts” call with Greg Klaas and Zach Sloven from Signet Partners in Denver on the RAD program. NMA and Signet are partnering on this important initiative to offer housing agencies a full package of services around RAD.
The Rental Assistance Demonstration Program — or RAD — is a pilot that allows housing agencies to “swap” traditional operating and capital grant funding for public housing to project-based rental assistance or project-based vouchers. Although additional funding is not available under the demonstration program, the way the subsidy is made available will make the program more interesting to potential lenders.
During our call on April 25th, we had about 30 callers from around the country who are interested in the RAD program. Greg Klaas provided a summary of the RAD program and discussed a few of the important points that will be necessary to consider should an agency apply during the demonstration program. We received a number of queries during the call and also emailed to me before, during and after the call.
Although there are too many questions to include them all here, I’ve provided a Q&A below that captures some of the most-often asked questions about RAD. We will be scheduling additional calls on this important program, and encourage you to check back on our blog and website for information regarding the dates and numbers for future calls.
Question 1: If there is no additional funding available to make loan payments, why bother applying for RAD?
Before deciding not to apply, it’s important to complete the pro forma included in the application. This exercise will identify the revenue, expenses and likely resources needed to make renovations at your property. Project-based assistance or project-based vouchers provide a more flexible source of funds to be used for loan payments.
Question 2: Under RAD, would a PHA begin to report to the multifamily office at HUD?
If a PHA is approved under RAD and uses project-based rental assistance, they would be “moved” for reporting purposes to the office of multifamily housing at HUD; if they use project-based vouchers, they would continue to work with the PIH office at HUD.
Question 3: Under the RAD program, the contract terms will be between 15 and 20 years. If an HA decides to sell the RAD project site in the future, does the PBV remain with the project and/or is the subsidy transferable?
Although not specifically covered in the proposed notice, projects with loans and subsidy in place are routinely transferred at the time of a change in ownership.
Question 4: Does the current Physical Needs Assessment that an HA may have meet the criteria under RAD for a Property Condition Assessment as outlined in the proposed notice?
No, currently a PNA does not include the energy efficiency criteria (or green initiatives) that are a part of RAD. The current PNA would be helpful in identifying the needs of the project site for the application phase of RAD. If the HA is selected into the program, then at that point a GPCA would be needed.
Question 5: Will supportive services grants such as FSS or PH ROSS be transferable (converted to S8 FSS/ROSS) to the PBV units or will these grants be terminated through this transition process?
This situation is not included in the proposed notice, so it would be best to check if RAD would require forfeiture of these grants with the office most familiar with the funding.
Question 6: Is there a minimum number of units required to apply under RAD?
No, there is not a minimum number of units required to make a RAD application. However, if an HA finds that it will need other funding resources once selected for RAD and applies for additional funding through loans or four percent tax credits, it’s likely that a minimum unit count would be necessary, because of the time and expense involved in these funding processes.
With over 30 years of experience in the affordable housing industry, VP of Professional Services Carrol Vaughan ensures that NMA continues to help PHAs better serve their communities.
Please check back for additional information and Q&A on RAD. We will provide blog posts as more information is forthcoming and will be scheduling additional calls in future months.
To learn more about how NMA can help with RAD applications, visit our website.
May 2, 2012 Leave a comment
Many PHAs have a requirement for short- or long-term operational support to ensure the effective delivery of services for their HCV and public housing programs.
This might range from the provision of short-term operational line staff coverage while in-house resources are unavailable or tasked with other responsibilities, to providing interim executive positions to lead your organization through the transition process.
When choosing an operational support provider, it’s important to consider companies that can provide experienced resources and a proven track record of success. Potential providers should also be able to:
For further reading, you might find these links useful:
As an NMA consultant, Andrew Denicola has assisted large HCV programs with the development and implementation of comprehensive quality control protocols, as well as the ongoing development of streamlined policy and procedure for multiple PHAs. In his current role as strategic sales and business development manager, Mr. Denicola provides a knowledgeable liaison to the assisted housing industry.
Whatever your requirements, Nan McKay and Associates can provide experienced, qualified people to ensure the integrity and stability of your operation or to help with the management and focus of your PHA’s activities. Contact sales@nanmckay.com to learn more.
April 27, 2012 Leave a comment
Affordable Housing Finance: Top 50 affordable housing developers
Education Week: Study links zoning to education disparities
NHC: Public housing continues to play leading role in green construction
Leave your links and recommendations in the comments.
April 23, 2012 Leave a comment
Tip #5: Check that the information you’re transmitting to PIC is accurate.
For every rent calculation on form HUD-50058 submitted to PIC, there’s an FSS addendum. Its purpose is to transmit information regarding the FSS program, including whether anyone has started or ended the program (completions, drop-outs, terminations) as well as information on services provided and escrow accounts.
It’s extremely important that this information is accurate in the PIC system, so that you’re funded appropriately. Check the report! You can pull it directly off the Internet from the PIC system.
If you discover that the information in your PIC report doesn’t match what you have in your hard copy files or FSS administration files, work with the PIC contact at your housing authority to fix it. They’ll need to know what the errors are, and you’ll need to provide them with hard copy data, which HUD requires before making any changes. They can then contact the PIC coach in the field office and work with them until the information is corrected.
Remember, HUD goes by what’s in the electronic PIC data. If their data says you don’t meet the criteria for an FSS coordinator grant, it doesn’t matter what your hard copy files say — you don’t qualify for the grant.
Additionally, if your data is clearly incorrect (for example, says you have 2,000 people enrolled when you’re a small PHA), HUD has been known to deny grants on those grounds as well.
To sum up, the five tips I’ve discussed are:
Each of these tips contributes to running a better FSS program in its own right, but you may notice that each ties into one another. A strong understanding of the program goal is crucial for a consistent service delivery design and an effective PCC. Apply these tips together in order to achieve great results.
In her capacity with the San Diego Housing Commission, NMA Senior Associate Trainer Patti Zatarain-Menard designed, developed, and implemented one of the nation’s largest and most successful family self-sufficiency programs. For the past two decades, she has worked with Nan McKay and Associates conducting training seminars nationally and undertaking consulting assignments on federally subsidized housing.
If you find that you need assistance in maintaining a successful FSS program or setting up your FSS action plan, NMA can help. Email sales@nanmckay.com for more information.
