NMA Blog

The importance of updating PHA policies

HUD issues new regulations, notices, and guidance on an ongoing basis, and PHAs are expected to stay abreast of these changes to remain in compliance and avoid audit findings. However, making sure your agency’s policy documents are in line with HUD can be a daunting, time-consuming task—not only do you need to know what’s changed and why, but you must also revise your policies accordingly.

PHAs who are out of compliance—depending on the reason—may be subject to monitoring and sanctions, or worse, lose out on program funding. Fair housing complaints can result from a lack of clear and current policies, and in the Housing Choice Voucher program, some incorrect policies can affect SEMAP as well.

Fortunately, there’s a solution. Our model policies and revision services take the guesswork out of keeping your policies up-do-date and in compliance, providing you with expert guidance in a timesaving, user-friendly format.

Our writing team has been working hard to make our policy updates available immediately, so our revision services customers don't have to wait to receive a CD with updates in the mail. (And a lot of our customers don't even have CD drives anymore to access the files with!)

With that in mind, we've created a new site where agencies who have signed up for policy updates can access the files as soon as we upload them. If you're a subscriber, you should have received an email with your login information. If you haven't, please contact revisions@nanmckay.com.

The new site will include policy updates for the following products:

• NMA Model Admin Plan and Guide
• NMA Model ACOP and Guide
• NMA Model Tenant Selection Plan (TSP) and Guide

It will also provide:

• Our searchable and updated CFRs as a free service for all revisions subscribers
• Two years of back policies for subscribers who may need to catch up
• A hands-on video to help you step-by-step through the download process

If you're a subscriber to our model admin plan updates, you can get on the site now and download the brand-new 2018 revision! The model plan has been brought current with all recent HUD requirements and guidance, including the following:

• Changes to account for the updated administrative guidance for the effective and mandated use of the EIV system, as outlined in Notice PIH 2017-12
• Updates concerning Notice PIH 2017-13, which discusses the Lead Safe Housing Rule as it relates to elevated blood lead levels (EBLLs) in the Housing Choice Voucher (HCV) and Project-Based Voucher (PBV) programs
• Revisions for the implementation guidance on the Housing Opportunity Through Modernization Act of 2016 (HOTMA) HCV and PBV provisions described in Notice PIH 2017-21
• Modifications pertaining to the interim final rule published December 12, 2017, which implemented the Fixing America’s Surface Transportation (FAST) Act, slightly revising some of the streamlining options allowable under the streamlining final rule from March 2016
• Changes for guidance set forth in Notice PIH 2018-01 on recent changes in Fair Market Rent (FMR) payment standard, and rent reasonableness requirements

The 2018 model ACOP revisions will be posted in a few weeks.

QUESTION     What are the requirements for training on the EIV system for newly-hired staff members? Is it true that they must receive EIV training within one week of their start date? I can’t find a reference for this.

ANSWER     It is not true that new hires must complete training on HUD’s Enterprise Income Verification (EIV) system within one week of employment. However, PHA staff must complete the training prior to accessing the EIV system itself or EIV printed reports.

The current reference is in Notice PIH 2017-12, Administrative Guidance for Effective and Mandated Use of the Enterprise Income Verification (EIV) System:

EIV System Training Information. As a condition of initial and continued access to the EIV System, HUD and PHA staff are required to complete Annual Security Awareness training and EIV system training (initial system training) and update (interim system changes) training when offered by HUD Headquarters (HHQ). This training requirement also applies to those individuals who will not access EIV, but will view or handle printed and/or electronic EIV data. Individuals who will view and/or handle printed EIV information are required to complete only annual Security Awareness training (EIV system training is optional for these individuals). EIV training provided by third parties (other than HUD Headquarters) does not fulfill the mandatory EIV training requirement.

EIV system users who need to complete EIV training may view EIV training webcasts at: http://portal.hud.gov/hudportal/HUD?src=/press/multimedia

Note: Employees must complete the training prior to accessing the EIV system and/or printed EIV reports.

It should be noted that this guidance differs from that in the previous notice, PIH 2010-19. The older notice required EIV training to be completed by set dates depending on date of hire. It’s also important that two types of EIV training are required: initial system training and annual security training.

Are you a PIH Alert subscriber? Every Friday, the PIH Alert includes one frequently asked question (FAQ) submitted by our readers. Sign up today for a free 30-day trial subscription! Email sales@nanmckay.com to get started. To submit your question, email Annie Stevenson at annie@nanmckay.com with the subject line "FAQ Friday."

NMA is pleased to announce the debut of the NMA Model EIV Use and Security Policies for HUD’s multifamily housing programs! These policies make an excellent companion for the NMA Model Tenant Selection Plan (TSP) and Guide, which joined our existing family of model policies, including the model administrative plan, the model ACOP, and the model FSS action plan, earlier this year.

For those developments participating in HUD's multifamily program, the EIV use and security policies provide guidance on the protocol for the use of EIV information and printed reports, as well as the rules for maintaining tenant privacy and document security. With our user-friendly model policies, owners of project-based rental assistance (PBRA) projects will not only be certain they have current and compliant policies, but also potentially save hundreds of hours of work.

Many PHAs are asking, "What does the shutdown mean to our agency and the families we serve?" Yesterday, the Department of Housing and Urban Development (HUD) posted a 67-page contingency plan which provides some guidance to PHAs on the impacts of a lapse in appropriations due to the federal government shutdown.

According to the contingency plan, PHAs will continue to be able to access HUD's Office of Public and Indian Housing (PIH) secure systems, such as the Voucher Management System (VMS), the PIH Information Center (PIC) system, the Enterprise Income Verification (EIV) system, and the Line of Credit Control Systems (LOCCS), among others. However, although HUD's PIH systems will be largely available, PIH staff and contractors will not be available to answer questions regarding the systems. RAD applications will continue to be accepted, but they will not be reviewed until after the shutdown.

HCV housing assistance payments and administrative fee funding for the month of October are scheduled to be disbursed to PHAs according to the regular schedule, but any November funding is contingent upon the outcome of the government shutdown. Any public housing operating subsidy or capital funds that have already been obligated through LOCCS can be drawn down, but additional funding is also contingent on the shutdown. As a result of the funding uncertainty, PHAs should carefully monitor their financial situations throughout the government shutdown.

• PIH staff will not be attending any meetings or conducting monitoring or technical assistance visits at PHAs
• REAC inspections will not be conducted
• PIH staff will not be available to answer any non-emergency questions from PHAs, residents, or others
• Contact information for PIH emergency operations during the government shutdown will be posted on the HUD website

For further details on the portion of the contingency plan that concerns programs administered by PIH, see pages 7 and 57–63. NMA will continue to update the blog as more information on the government shutdown becomes available.