Post on 01-Jan-2016
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General Discussion SEMAP Utilization Income Rent Reasonableness HQS Portability Lead-Based Paint
SEMAP CHANGE
Indicator 14 – Utilization
Federal register notice (May 31, 2012)
Effective for FYE 6/30/12 PHAs
Allocated Budget Authority = PHA Eligibility
Homeownership
Notice PIH 2012-3
Reminder to PHAs to exclude from assets a home purchased with voucher assistance for the first 10 years after the purchase date.
The Notice breaks down how to determine market value, loan or mortgage balance, and cash value of an asset.
Homeownership Cont.
Market value - determined in various ways
(1) comparable sales in the area(2) online resources such as
http://zillow.com(3) reviewing local assessments (4) most recent tax assessor’s
determination. Be consistent and include in the Administrative Plan.
Homeownership Cont.
Loan balance - look at the most recent monthly mortgage statement; the PHA may rely upon the loan balance in lieu of an actual payoff amount for calculating asset value.
Other factor - cost to convert the asset to cash. This cost must be deducted from the equity valuation. The PHA may use a flat percentage of up to 10% of the value of the asset as a cost to convert to cash, in lieu of calculating actual costs
Passbook Savings Rate
Notice PIH 2012-29
PHAs may establish a passbook rate within 75 basis points (plus or minus .75 percent) of the Savings National Rate in effect at the time the PHA establishes the passbook rate. (Safe harbor)
Must review annually www.fdic.gov/regulations/resources/rates/
Income Exclusions
Notice PIH 2012-1: Kinship Guardian Assistance Payments (Kin-GAP) and similar state guardianship care payments
Revised Federally Mandated Exclusions from income – Published 7/24/12
Removed - Payments received under Job Training
Partnership Act- Allowances for children of Vietnam
veterans with spina bifida
Income Exclusions Cont.
Added – Assistance under the School Lunch Act and Child Nutrition Act– Payments under the Seneca Nation
Settlement Act– Payments from any Department of
Veterans Affairs disability benefits received in lump sum or prospective monthly amounts
– Lump sums or periodic payments to an individual Indian from Elouise et al. vs. Ken Salazar et al.
Income Verification
1. Upfront Income Verification (UIV) – EIV Mandatory Item 4 also required
2. UIV – non HUD3. Written third Party Verification High
(Mandatory to supplement EIV-reported income sources and when EIV has no data; Mandatory for non-EIV reported income sources; Mandatory when tenant disputes EIV-reported employment and income information and is unable to provide acceptable documentation to support dispute)
Income Verification Cont.
4. Written Third Party Verification Form Medium-Low
(Mandatory if written third party verification documents are not available or rejected by the PHA; and when the applicant or tenant is unable to provide acceptable documentation)
5. Oral Third Party Verification Low6. Tenant Declaration Low
Last resort
Zero Income Worksheet
Used to identify unreported income
Should not just use the results as Income Should question resident about sources and
obtain verification or certification from resident
EIV/PIC
Deceased Tenant Report – Notice PIH 2012-4 requires PHAs to generate the Deceased Tenants Report at least once a month prior to disbursing the upcoming monthly housing assistance payment (HAP) to owners.
Timely submission – Notice PIH 11-65 must be submitted no later than 60 calendar
days from the effective date of any action recorded on line 2b
Implemented use of voucher issuance code
HQS
Notice PIH 11-29 – Guidance on HQS Inspections
1.Verification of HQS Deficiency CorrectionWhat is the definition of VerifyExceptions
New UnitsProject based units
2.Electrical Receptacles two-prong or three-prong receptacles
HQS & LBP
Notice PIH 11-29 – Guidance on LBP Management of the HQS inspection
process Quarterly matching process between
the local health authority and the PHA is identifying EIBLL children
Clearance exams are being conducted Owner certification of compliance
(when required) PHAs are checking owner compliance
with disclosure requirements
Rent Reasonableness
Notice PIH 2011-46
This Notice clarifies the definition of assisted and unassisted housing when determining the reasonableness of proposed rents
Rent Reasonableness
Assisted units (excluded) include: Units assisted under a Federal, State, or local
government program Rents and/or rent increases are controlled or
restricted by law or a court order Units occupied by tenants on the date of an
eligible Housing Conversion Action that receive lower rents or concessions
Reduced rents for resident managers (if common practice)
Long term tenant rents that have not increased because of owner policy or local ordances
Rent Reasonableness
When is a rent reasonableness determination required
Prior to initial lease-up of a unit Before any increase in the rent to owner if there is a five percent or more decrease in
the published Fair Market Rent (FMR) in effect 60 days before the contract anniversary
If directed to do so by HUD.
Waiting List
Notice PIH 2012-34 – issued 8/13/12
Required information (Opening the list) Time and place Limitations on who can apply Other needed information
Other considerations Ensure notice reaches
Individuals with disabilities Individuals with limited English proficiency
Waiting List Cont.
Placement on the list All applicants Lottery Other random choice technique
Section from the list Date and time Drawing or other random choice
Waiting List Cont.
Accepting Applications One site; Multiple sites; Mail; Email; WEB; Fax;
Telephone; etc.
Outreach Local Welfare offices; Homeless shelters;
Domestic Violence shelters; Minority organizations; etc.
Social Media; Newsletters; other WEB sites; On-site visits; etc.
Social service agencies; Nursing homes; Psychiatric hospitals; Medicaid agencies; etc.
Portabilty
Notice PIH 2011-3
When can a move be denied? Family has not lived in the jurisdiction for 12
months Lack of funds and receiving PHA is not absorbing Action or inaction by the family (must deny if
moved out of assisted unit in violation of the lease, exception for VAWA)
New admission is not income eligible in port area
Not in compliance with PHA policies on timing and frequency of moves
Portability Cont.
Denial for Insufficient Funds REQUIRES HUD FO notification prior to denial
HUD Notification requirementsFinancial Analysis demonstrating insufficient funds excluding any outstanding vouchers (Spreadsheet at http://www.hud.gov/offices/pih/programs/hcv
Certification that voucher issuances have ceased and no admissions from the waiting list will be made while moves are restricted
A copy of PHA’s policy on how PHA will address families that have been denied moves
Portability Cont.
Penalties for inappropriate denial of portability
Up to a 10% reduction in admin fees for the two quarters after HUD discovery
Other remedial actions or sanctions as determined by HUD
Portability Cont.
Notice Requirements The initial PHA (IP) must notify receiving
PHA (RP) by email or other confirmed delivery method
The RP must notify IP by email or other confirmed delivery method on intent to bill or absorb
The IP contacts the RP on family’s behalf (Telephone, fax, email) (give family contact info foe RP)
Mail/fax HUD-52665, copy of voucher, and income verification
Portability Cont.
Deadlines
RP must promptly issue a voucher (2 weeks)
Initial billing notice must be mailed (includes fax; email) within 10 working days of HAP contract execution but no later than 60 days after original voucher expiration
If billing is not received timely, the IP must notify the RP in writing that it will not accept a late billing
Portability Cont.
Deadlines Cont.
IP must pay initial bill within 30 calendar days
Subsequent payments are due by the 5Th working day of each month
RP must submit up dated 50058 within 10 working days of the effective date of the annual reexam
RP must submit up dated 50058 and 52665 within 10 working days of the effective date of any change in billing amount
Portability Cont.
Deadlines Cont.
RP must notify the IP within 10 working days of the effective date of termination of HAP payments or absorption of the family
Portability Cont.
Responsibilities of the IP and RP
Voucher extensions Voucher size Subsequent port to another PHA Income Limits