NMA Blog

Subscribers to our annual revision service can expect to receive the latest updates to the NMA Model Admissions and Continued Occupancy Policy (ACOP) and Guide this week. If you have any questions about your subscription, please contact Meg Kennedy in our accounting department and she'll be happy to assist you.

Most of the changes for the 2014 revision were made necessary by the publication of the Federal Register notice regarding the Violence Against Women Reauthorization Act of 2013 (VAWA), issued August 6, 2013. The notice stated that the provisions of VAWA 2013 were not self-implementing, and that HUD would issue rules or guidance at a later date. However, on September 30, 2013, HUD sent a letter to PHA executive directors which called for immediate policy development addressing certain provisions of VAWA 2013.

In response to HUD’s letter, NMA has developed transitional model policies to assist our subscribers in meeting this HUD requirement. Please note that once HUD issues the expected guidance, additional changes may be required. In addition to the extensive VAWA changes, the 2014 revision has been brought current with all recent regulatory requirements and guidance and also includes:

• Extensive policy changes concerning flat rent requirements mandated under the 2014 appropriations act and outlined in Notice PIH 2014-12 and its accompanying PIH-issued FAQs
• Updated policies regarding service animals, assistance animals, and pets, incorporating the latest guidance including Notice FHEO 2013-1
• A revised definition for extremely low-income (ELI) family, as per the Federal Register notice published June 25, 2014
• Updates to account for the issuance of Notice PIH 2013-26, which extends the temporary compliance provisions of 2013-03
• Updates to the list of federally mandated income exclusions as published in the Federal Register
• Minor modifications for clarification and wording

Looking for further guidance? NMA can help rewrite your ACOP in only three days.

NMA revision services provide a yearly update to your NMA Master Books and model policies with explanations and guidance regarding the most current HUD rules and regulations. To stay updated on the latest program information, try a free 30-day trial subscription to the PIH Alert. Email sales@nanmckay.com to get started.

We’re pleased to announce the release of NMA's seminar calendar for the fourth quarter of 2014. You can view a list of the training opportunities that Nan McKay and Associates is offering from now through the end of December on this page at our website. Start planning your autumn training now and save! If you register at least 45 days in advance for most seminars, you’ll receive a 10 percent discount. (The discount does not apply to seminars hosted by housing authorities or associations.) Our seminars have been updated for:

• Notice FHEO 2013-1, issued April 30, 2013, which provided new guidance regarding service animals, assistance animals, and pets
• The Federal Register notice published August 6, 2013, which provided an overview of the Violence against Women Reauthorization Act of 2013 (VAWA 2013) as it applies to HUD programs
• The final capital fund rule, published October 24, 2013
• Notice PIH 2013-26, issued November 5, 2013, which extends the temporary compliance provisions of 2013-03
• Notice PIH 2014-12, the flat rent interim notice mandated by the 2014 appropriations act, issued May 20, 2014
• The Federal Register notice implementing other program changes contained in the 2014 appropriations act, including biennial inspections, issued June 25, 2014
• The final rule implementing changes from the Housing and Economic Recovery Act of 2008 (HERA), published June 25, 2014
• And more!

Having trouble finding the class you want? We can bring the seminar to you. Email sales@nanmckay.com for more information about our affordable onsite training options.

Subscribers to our annual revision service can expect to receive the latest version of the NMA Public Housing Management (PHM) Master Book this week. If you have any questions about your subscription, please contact Janell Guilbeaux in our accounting department and she'll be happy to assist you.

The issuance of the final capital fund rule in October 2013 prompted major revisions to the PHM Master Book. In addition to those changes, the 2014 revision also includes:

• New guidance for ensuring compliance with Notice PIH 2014-12, the flat rent interim notice mandated by the 2014 appropriations act
• Extensive changes throughout the book for the Violence Against Women Reauthorization Act of 2013 (VAWA)
• A new section for service animals, assistance animals, and pets, incorporating the latest guidance including Notice FHEO 2013-1
• Updates to account for the issuance of Notice PIH 2013-26, which extends the temporary compliance provisions of 2013-03
• Updates to the list of federally mandated income exclusions as published in the Federal Register
• Other minor modifications and reorganizations for clarification and wording

Looking for further guidance? Don't miss our blog series: Working with Sequestration in the Public Housing Program. You may also be interested in our Public Housing Management class, which has also been thoroughly updated for the final capital fund rule as well as all bulleted items above.

NMA revision services provide a yearly update to your NMA Master Books and model policies with explanations and guidance regarding the most current HUD rules and regulations. To stay updated on the latest program information, try a free 30-day trial subscription to the PIH Alert. Email sales@nanmckay.com to get started.

In a press release yesterday, the Department of Housing and Urban Development (HUD) announced the issuance of a notice on assistance and service animals by its Office of Fair Housing and Equal Opportunity (FHEO). Notice FHEO 2013-1 is divided into three sections:

• Section I explains the obligations that housing providers have under the Fair Housing Act and Section 504 of the Rehabilitation Act of 1973 to provide reasonable accommodations to persons with disabilities who need assistance animals. This section includes a two-question test that housing providers with a no-pets policy can apply to determine whether or not the Fair Housing Act and Section 504 require a modification to that policy.
• Section II explains the revised definition of service animal adopted by the Department of Justice (DOJ) in its regulations implementing the Americans with Disabilities Act (ADA).
• Section III explains the obligations of housing providers subject to both the service animal requirements of the ADA and the reasonable accommodation provisions of the Fair Housing Act and/or Section 504.

In another press release yesterday, HUD and the Department of Justice (DOJ) announced the publication of a joint statement on accessibility (design and construction) requirements for covered multifamily dwellings under the Fair Housing Act. The 31-page joint statement is intended “to assist design professionals, developers, and builders in understanding and meeting their obligations and to assist persons with disabilities in understanding their rights.” It consists of a brief introduction and the answers to 63 questions on the following topics:

• Accessibility requirements of the Fair Housing Act
• Types of dwellings covered by the Fair Housing Act
• Ground floor dwelling units
• Single-story and multistory dwelling units
• Additions
• Alterations/renovations
• Building separations
• Dwelling units custom-designed or presold prior to completion
• Subsequent changes to accessible features
• Buildings with one or more elevators
• Accessible routes
• Accessible entrances
• Safe harbors for compliance with the Fair Housing Act
• Reviews for compliance
• Buildings covered by the Fair Housing Act and other accessibility laws or codes
• Accessible public and common use areas
• Enforcement
• Reasonable accommodations and reasonable modifications under the Fair Housing Act
• Location of documents

Do you have concerns about whether or not your agency is compliant with federal fair housing law? Nan McKay and Associates can help. Our resources for your PHA include consulting, a newly-updated video, and a training seminar, also newly updated.