NanMcKay-logo


All Topics     |     Industry News     |     Knowledge Base     |     Company News     |     Product Updates

Ensuring up-to-date policies

Posted by Kaylene Holvenstot on Jul 11, 2019 7:15:00 AM

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.

NMA’s Model Policy Revisions

This July, NMA will be releasing the 2019 revisions of our Model Administrative Plan and Model Admissions and Continued Occupancy Policy (ACOP). For this year’s revisions, these model policy documents contain updates for:

  • Notice PIH 2018-01 on the voluntary adoption of the use of Small Area Fair Market Rents (SAFMRs)
  • Notice PIH 2019-09 on the treatment of ABLE Accounts
  • Notice PIH 2019-11, which requires PHAs to publish and update public housing over-income limits in the ACOP
  • Notice PIH 2018-18, which updated HUD’s Verification Hierarchy
  • Notice PIH 2018-19, which established minimum heating standards in public housing
  • Notice PIH 2018-24 on verifying Social Security numbers, Social Security and Supplemental Security Income (SSI) benefits, and the effective use of the EIV Identity Verification Report
  • Other clarifications and modifications to make sure the content is user-friendly, current, and in compliance with all HUD regulations and guidance

In other words, when you subscribe to the NMA Model Admin Plan or ACOP, we do the heavy lifting of updating your policies for you—potentially saving your agency hundreds of hours of work.

For each area in which your agency has discretion or flexibility, NMA model policies provide recommended language. Also, the accompanying instruction guide offers important points to consider for each policy and customizable policy choices so that you can choose the best policy to suit your agency’s needs.

All of our model policy documents cite and describe the most up-to-date HUD regulations and other requirements in detail, which presents your agency with a solid foundation in policymaking. Further, when you subscribe to the revision service, you can rest assured that your policies remain current with HUD’s most recent changes every year.

The new NMA revisions website

Remaining up to date with a subscription to the NMA Model Administrative Plan or Model ACOP revision service is now easier than ever. Last year we went completely digital with our model policy revisions, moving access to a new website, and this year we’re making our Master Book revisions available through the site as well.

On the new revisions site, each policy or Master Book revision to which an agency subscribes is available for digital download all in one convenient location. This not only eliminates the need for awkward discs or drives, but also allows subscribers to access their revisions online immediately after they are finalized.

Should you miss a revision, the site provides access to the two previous years’ revisions as well, in addition to providing access to other added features such as our searchable CFRs.

Tools like our model policies and their revision services are designed to ensure that you always have the most accurate and up-to-date information. Through these and our other products and services, we at NMA will always strive to find ways to assist you in the successful administration of your housing programs—both now and through whatever changes may come.

 

Learn more about  NMA's model policies

Find NMA's model  policy revisions here

 

Topics: books and revision services, EIV, over-income families, SAFMR

HUD publishes 2019 FMRs

Posted by Annie Stevenson on Sep 5, 2018 3:35:33 PM

In a notice published Friday in the Federal Register, HUD announced that it has published fair market rents (FMRs) for federal fiscal year (FFY) 2019 (October 1, 2018 through September 30, 2019). As explained in the notice:

Section 8(c)(1) of the United States Housing Act of 1937 (USHA), as amended by the Housing Opportunity Through Modernization Act of 2016 (HOTMA), requires the Secretary to publish FMRs not less than annually, adjusted to be effective on October 1 of each year. This notice describes the methods used to calculate the FY 2019 FMRs and enumerates the procedures for public housing agencies (PHAs) and other interested parties to request reevaluations of their FMRs, as required by HOTMA.

The deadline date for comments on the 2019 FMRs is October 1, 2018. The revised FMRs will be effective on October 1, 2018 (unless HUD receives a request for reevaluation of specific area FMRs).

Materials posted today on PD&R’s FMR page include the FFY 2019 FMRs for all areas (see Schedule B) and the FFY 2019 small area FMRs (SAFMRs) for metropolitan FMR areas (see Schedule B addendum).

HUD has also posted a schedule of unadjusted rents, which are used for setting public housing flat rents in non-metropolitan areas. The accompanying county-level data set was also posted to the FMR page. HUD no longer publishes exception FMRs for manufactured home spaces in the HCV program since PHAs now use their regular FMRs/SAFMRs for subsidy determinations.

Learn more about how to  correctly calculate rent

Topics: flat rent, FMR, HOTMA, SAFMR

HUD Releases Additional Resources on SAFMR Implementation

Posted by NMA on Mar 21, 2018 2:23:09 PM

Recently on HUD Exchange, the Department of Housing and Urban Development (HUD) posted several new resources to aid in the implementation of the Small Area Fair Market Rents (SAFMR) final rule. Chief among these resources is a new guidebook, which provides guidance and practical examples for PHAs implementing SAFMRs. Topics covered in the guidebook include the policy background of SAFMRs, how SAFMRs will affect payment standards, and administrative and programmatic impacts of the rule.

In addition to the guidebook, HUD has also posted several other resources providing additional information and guidance on the rule. These include:

You can find links to all of these resources here, on the Small Area Fair Market Rents webpage, at HUD Exchange.

Does SAFMR implementation sound like a headache for your time-crunched, budget-burdened agency? Let us take on that project for you. We’ll conduct rent burden analyses, analyze vacancy rates, and conduct other required actions to ensure you’re in full compliance with all HUD rules and regulations. Click here to learn more

Topics: FMR, Industry News, SAFMR

HUD Issues Guidance on SAFMR Final Rule

Posted by NMA on Jan 25, 2018 5:00:00 AM

HUD’s Office of Public and Indian Housing (PIH) recently issued Notice PIH 2018-01 providing guidance on recent changes in fair market rent (FMR), payment standard, and rent reasonable requirements set forth in the Small Area FMR (SAFMR) final rule. As you know, in August of last year HUD exercised its authority to suspend SAFMRs for 23 out of the 24 designated areas that would have gone into effect on October 1, 2017. However, in late December, the U.S. District Court for the District of Colombia entered a preliminary injunction voiding that suspension, meaning that the mandatory use of SAFMRs is now in effect for all 24 areas (listed in Appendix A of the notice). PHAs must now complete the SAFMR implementation as quickly as possible—no later than April 1, 2018. The notice is meant to help with that task, allowing PHAs to better understand their options under the final rule.

  • The notice primarily summarizes the changes and requirements specified in the final rule, with some examples and additional guidance provided for implementation purposes. Highlights include, but are not limited to, the following:
  • he notice provides scenarios that may apply when a new payment standard schedule goes into effect, i.e., specifically when to use the old vs. the new payment standard schedule.
  • HUD recommends that PHAs provide both the old and new payment standard schedules to families issued a voucher whose search term extends beyond the effective date of the new schedule.
  • PHAs adopting an exception payment standard area must revise their briefing materials to make families aware of the exception payment standard and the area it covers.
  • The notice provides policy possibilities that may be adopted if there is a decrease in the payment standard schedule during the term of a family’s HAP contract.
  • Where the PHA chooses to reduce the payment standard for a family under HAP contract, the initial reduction cannot take place before the effective date of the family’s second regular reexam following the effective date of the decrease—meaning PHAs must conduct a reexamination of family income and composition at least annually. This is the case even if the PHAs had implemented a streamlined income determination for fixed-income families.
  • Notice to families is required for any reduction in payment standard, even if choosing to do so gradually. Appendix B of the notice provides tips for strengthening written notices to such families.
  • HUD recommends that any agency required to adopt SAFMRs review the SAFMRs for the fiscal year prior to mandatory adoption to estimate the effect of moving from metropolitan area FMRs (MAFMRs) to SAFMRs, and to use this to inform its policy.
  • The notice provides various considerations PHAs can use to evaluate whether to “opt in” to using SAFMRs. Of course, such agencies must request approval from HUD to voluntary adopt SAFMRs.
  • The notice provides examples of “grouping” by ZIP code areas for agencies adopting SAFMRs, since the percent of the SAFMR that the payment standard equals may vary between different unit sizes and from ZIP code area to ZIP code area, and PHAs have the flexibility to do so.
  • The notice also offers various considerations and recommendations for whether an agency should adopt SAFMRs for its Project-Based Voucher (PBV) program, including examples.
  • The vouchers of families who port will be administered according to the policies of the receiving PHA (RHA)—if the RHA is operating under SAFMRs, the family’s voucher will be administered using SAFMRs. If the RHA is not, the family’s voucher will not.
  • If the use of SAFMRs has been designated for a metropolitan area or the PHA has voluntarily chosen to use SAFMRs, the SAFMRs would apply to all tenant-based vouchers, including special housing vouchers such as single room occupancy (SRO) and the homeownership option.
  • MTW PHAs are exempt from the requirement to use SAFMRs if that agency has an alternative payment standards policy in its HUD-approved Annual MTW plan.
  • With regard to the transition out 50th percentile rents over a three-year period, if the PHA scored the maximum number of points on the SEMAP deconcentration bonus indicator in the prior year or in two of the last three years, then upon expiration of the three-year period, the PHA may request HUD approval of payment standard amounts based on the 50th percentile rent. The request must be made to the local HUD field office during the period between the release of the revised FMRs and the effective date of those FMRs.
  • For PHAs requesting a suspension of the SAFMR designation for the metro area due to an adverse housing market condition, the PHA must administer more than 50 percent of the vouchers leased in that metro area. The notice also defines what constitutes an adverse housing market condition.

In addition to developing this guidance, HUD has also established a set of FAQs specific to SAFMRs, available here. Questions may be sent to SAFMRs@hud.gov.

Does SAFMR implementation sound like a headache for your time-crunched, budget-burdened agency? Let us take on that project for you. We’ll conduct rent burden analyses, analyze vacancy rates, and conduct other required actions to ensure you’re in full compliance with all HUD rules and regulations. Click here to learn more

Topics: FMR, Industry News, SAFMR

HUD Announces SAFMR Implementation Effective January 1

Posted by NMA on Jan 8, 2018 3:30:58 PM

In an email from the Financial Management Center (FMC) on December 29, HUD announced that a federal district court has issued an order setting aside the suspension of the small area FMR (SAFMR) final rule. The rule, which impacts 24 metropolitan areas, was originally scheduled for implementation on January 1, 2018. On August 11 HUD announced that it had suspended mandatory implementation for two years, until January 1, 2020. A complaint filed in October by a Connecticut non-profit corporation resulted in a preliminary injunction setting aside the suspension.

The following is the full text of HUD’s December 29 email:

Dear Executive Director,

On December 23, 2017, a Federal District Court in Washington issued an Order in OCA vs. Carson (https://ecf.dcd.uscourts.gov/cgi-bin/show_public_doc?2017cv2192-29) setting aside the Secretary’s August 23rd suspension of the SAFMR Rule (https://www.huduser.gov/portal/datasets/fmr/fmr2016f/SAFMR-Final-Rule.pdf). Accordingly, this means that the implementation date is January 1, 2018. While HUD understands that some PHAs will be at a serious disadvantage regarding immediate implementation due to the suspension, PHAs must immediately take all steps necessary with respect to dedicating monetary and human resources towards the implementation; as well as integrating the new FMR requirements in any planning the PHA conducts. As expeditiously as possible, HUD will issue guidance addressing implementation issues, technical assistance, and potential obstacles to implementation.

Signed,
Milan Ozdinec

 

PHAs affected by this requirement must put together a new payment schedule that includes individual payment standards for each zip code. Our team of FMR experts is ready to take on that project for you, creating a new, compliant payment schedule without any additional workload for your staff. Click here to learn more

Topics: Industry News, SAFMR

Subscribe to our blog via email!    

Recent Posts

Posts by Topic

see all