PIH issues notice on 2015 op sub eligibility calculations and revised preliminary eligibility report for 2014

On Tuesday HUD’s Office of Public and Indian Housing (PIH) issued Notice PIH 2014-19 to provide instructions for the calculation of 2015 operating subsidy eligibility. The content of the notice is similar to the content of last year’s notice on the same subject (PIH 2013-16), but it’s not identical. For this reason, we recommend a close reading of the entire text. A few new and noteworthy additions:

• Because PHAs are no longer required to enter unit status data into HUD-52723s, the burden on PHAs ultimately will decrease as redundant reporting requirements are eliminated. In general, HUD anticipates only limited unit status changes. However, it is essential that PHAs ensure that all data on their operating subsidy forms are correct so as to provide for accurate funding. Agencies may work with their respective HUD field office to edit their unit status data.
• HUD will notify PHAs via the Financial Management Division (FMD)'s mailing list when it has generated its list of projects determined to be eligible for 2015 operating subsidy. If you see any errors on the list, you should notify your HUD field office within 10 business days after the list is published.
• No date is given for when the PIH office expects to deploy the 2015 Excel tools or when they will be due. The tentative submission schedule will be posted here.
• PHAs are reminded that operating subsidy provided to PHAs must be obligated by PHAs by the end of the calendar year for which it was appropriated. Thus, CY 2015 operating subsidy must be obligated by PHAs no later than December 31, 2015. Consistently, HUD appropriation acts have defined an obligation as a binding agreement that will require an outlay or expenditure of funds immediately or in the future. Because 24 CFR part 990 permits PHAs to accumulate reserves (referred to as excess cash in 24 CFR 990.280), disbursements of operating subsidy in LOCCS constitute both an obligation and expenditure. To the extent that a PHA has not disbursed all CY 2015 operating subsidy in LOCCS by December 31, 2015, it should maintain sufficient documentation to demonstrate that any balance remaining in LOCCS is obligated.
• HUD has partnered with the Environmental Protection Agency (EPA) to encourage PHAs to use the EPA’s Energy Star Portfolio Manager system to manage their utility consumption. To facilitate this, HUD is exploring ways to import data directly from EPA’s Portfolio Manager to prepopulate 52722 tools. HUD currently prepopulates 52722 tools with rolling base data, with PHAs entering data for the current year. HUD plans to roll out Portfolio Manager for PHAs to use on a voluntary basis in CY 2015. HUD will publish a notice providing instructions and guidance for PHAs interested in utilizing Portfolio Manager for CY 2015.

In an email sent today to the Financial Management Division (FMD) mailing list, HUD announced that it has posted a second preliminary eligibility report, post revisions, for the calendar year (CY) 2014 operating subsidy. The report has been posted to the CY 2014 operating subsidy website. According to the email:

This report reflects revisions submitted to date, as well as new projects.  This is one of the last opportunities PHAs will have to confirm that their eligibility amount is accurate.  PHAs should review the eligibility report immediately, and contact their field office if there is any discrepancy.

The email also states that today’s report does not include flat rent adjustments. A report with flat rent adjustments included will be posted shortly. To join the PH-FMD mailing list, click here.

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