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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

Two-Year Utilization Tool

Questions and Answers

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

Question & Answer