NMA Blog

NMA's revision services team has been working hard to get the latest editions of our model policies and Master Books written, published, and shipped to you!

2015: For 2015, the NMA Model Administrative Plan and Guide has been brought current with all recent regulatory requirements and guidance, including:

• The streamlining portability final rule, issued August 20, 2015, which includes changes to definitions, briefings, procedures, billing, and mandatory suspensions, among others
• The letter to executive directors dated September 15, 2015, which affects portability billing deadlines
• Changes to VAWA policy based on counsel from the National Housing Law Project
• Changes to policy on PHA-owned units in the project-based voucher program per Notice PIH 2015-05
• Removal of references to the certificate program due to the streamlining of 24 CFR Part 982
• Removal of outdated or expired guidance, such as the Protecting Tenants at Foreclosure Act and temporary compliance assistance
• Other minor modifications and clarifications to bring the content current with HUD regulations and guidance

2015: For 2015, the NMA Public Housing Master Book has been brought current with all recent regulatory requirements and guidance, including:

• Changes to the Community Service and Self-Sufficiency Requirement (CSSR) brought about by Notice PIH 2015-12
• Modifications regarding flat rent provisions set forth in the 2015 appropriations act, implemented in the Federal Register notice dated September 8, 2015 and Notice PIH 2015-13
• Updated citations to account for the final rule on affirmatively furthering fair housing
• Other modifications and corrections for clarification and wording

2015: The 2015 revision to the NMA Code of Federal Regulations on CD includes the following regulatory changes:

• Added 2 CFR Part 200 for the updated procurement regulations set forth by the joint interim final rule, “Federal Awarding Agency Regulatory Implementation of Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards”
• Removed most of 24 CFR Part 85 regulations, except where stated that these regulations have been redesignated as 2 CFR Part 200
• Revised 24 CFR Part 982 regulations for the housing choice voucher program, which has had all obsolete references to the Section 8 rental assistance certificate program regulations removed throughout, in addition to several additions and revisions to account for the final rule on streamlining the portability process
• Made regulatory revisions to several parts of 24 CFR to account for the changes brought about by the final rule on affirmatively furthering fair housing

Questions about your revision services subscriptions? Contact Laurie Durrett in our accounting department and she'll be happy to assist you.

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.

Today in the Federal Register, the Office of Management and Budget (OMB) published an interim final rule implementing new procurement standards for all federal agencies. The notice provides the following summary:

Implementation of this guidance will reduce administrative burden and risk of waste, fraud, and abuse for the approximately $600 billion per year awarded in federal financial assistance.

The result will be more federal dollars reprogrammed to support the mission, new entities able to compete and win awards, and ultimately a stronger framework to provide key services to American citizens and support the basic research that underpins the United States economy.

The parts of the rule that apply specifically to Office of Public and Indian Housing (PIH) programs are located on page 212. If you wish to submit comments on the interim final rule, you will find information following the “Addresses” heading in today’s notice. Comments are due by February 17. The rule will become effective on December 26, 2014.

Other big news this week was the passage of the Consolidated and Further Continuing Appropriations Act for 2015, which President Obama signed on Tuesday. You can read more about the funding bill here and here.

Housing Finance: Top stories of 2014

HUD: Julián Castro's statement on FY15 budget

To all our blog readers, a very happy holiday! This is the final news roundup of 2014, and we'll be back in 2015 to bring you up to speed on what's ahead in the new year.

Section 3 of the Housing and Urban Development Act of 1968 requires recipients of HUD funding to create job training, employment, and contract opportunities for low- and very low-income individuals. When you think of HUD funding, it's probably subsidized housing that comes to mind. However, HUD also provides financial assistance to community centers, libraries, parks, and local road improvement, among other things.

The intent of Section 3 is to provide these opportunities to the "greatest extent feasible," as outlined in 24 CFR 135.30. This means that other procurement considerations are subordinate to Section 3 goals, and that cost considerations are insufficient grounds for awarding contracts to firms that are not Section 3-compliant.

• Part I: Why does it matter?
• Part II: Is my PHA subject to Section 3?
• Part III: What are my PHA’s responsibilities?
• Part IV: Can you recommend some Section 3 best practices?

Can you recommend some Section 3 best practices?

1. As with any large-scale, long-range, and collaborative initiative, your PHA's Section 3 program should be planned out strategically. Not planning it out is planning to fail! Look at the mission, brainstorm SWOTs, identify stakeholders, assess gaps in your internal resources, and put together a project plan that includes responsibilities and timelines.

2. Collaboration begins within the PHA! Procurement can't do this alone. You'll also need to include resident initiatives, human resources, and finance — and your Section 3 efforts must be championed from the top down with strong and supportive leadership.

3. Self-sufficiency staff and programs are key internal partners. Do you have an FSS program? Tie in Section 3 to your residents' individual training and services plans (ITSPs). A ROSS program? YouthBuild? Public housing self-sufficiency projects? All your economic self-sufficiency programs and activities can contribute to Section 3 success.

4. Designate or hire a Section 3 coordinator. 'Nuff said.

5. Now you’re ready to creatively and effectively collaborate with community partners. Work with the people doing the work! They'll help make your Section 3 program successful. These crucial partners will help you design an effective Section 3 program, and will help outreach, recruit, train and ensure hiring. Consider forming a Section 3 advisory board and include decision makers and experts from your local city or county government, Department of Labor Workforce Investment Board, welfare agency, community colleges, skilled trades, and other key stakeholders. At least one public housing resident should be a participant on the Section 3 advisory board.

NMA senior associate Cara Gillette trains, consults, and provides technical assistance nationwide in fair housing, public housing management, hearings, economic self-sufficiency, and governing boards. Prior to joining NMA, she administered public housing and Section 8 waiting lists, served as hearing officer, managed public housing, and oversaw resident economic development programs at the San Diego Housing Commission. She has previously written for the NMA blog on how to work with sequestration in the public housing program.

Looking for further guidance? We can bring our Procurement and Section 3 seminar to your PHA. Email sales@nanmckay.com for more information about our affordable onsite training options.

To help you squeeze the most out of your scarce training dollars, Nan McKay and Associates will be offering two of its most popular seminars right after the second annual NMA and GoSection8 Housing Conference this August in Chicago:

• Developing and Managing Project-Based Vouchers (click here to register)
• Procurement and Section 3 (click here to register)

The NMA Housing Conference will take place on Monday and Tuesday, August 18–19. The seminars will begin on Wednesday, August 20, and wrap up on Friday, August 22. If you register for the conference, you’ll save 20 percent on the price of either seminar. Plus you’ll get to spend a whole week in the Windy City!

2014 NMA and GoSection8 Housing Conference

August 18–19 at the Marriott Chicago Downtown

540 North Michigan Avenue, Chicago, Illinois

Visit our website to register!

Register online or email sales@nanmckay.com for more information. Don’t delay, hotel room block ends July 25!

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