FMRs are used in setting Housing Assistance Payments in the Housing Choice Voucher program and for a variety of purposes, including rent setting, in other programs. Currently HUD must release proposed FMRs by summer in order to allow sufficient time for public comment before October 1, the statutory deadline for the release of final FMRs. This schedule means HUD is currently unable to use the most recent American Community Survey data, which become available in the fall and are collected the previous year, and must instead use data that are two or more years old.
In this vein, NLIHC’s comments also acknowledge that even in doing away with the proposed FMRs, it may be necessary for HUD to deviate from the current October 1 deadline for the release of the final FMRs if it is to use the most recent ACS and other data. A HUD proposal included in the President’s FY12 budget request would simply eliminate any statutory deadline. NLIHC, however, finds that although HUD should have greater flexibility, an alternative hard deadline for the release of the final FMRs should still be required. NLIHC’s comments in this regard cite the recent delays in the release of income limits, which do not face such a hard deadline and still have not been released for 2011. NLIHC also reiterates its position that any substantial change to the data or method used to calculate the FMRs must still be proposed in the Federal Register and made available with sufficient time for public comment.
To see NLIHC’s full comments including responses to 11 technical questions HUD asks in its request for comments, visit http://www.nlihc.org/doc/NLIHC_Comments_FMRs.pdf