PIH Notice Provides Voucher Funding Shortfall Guidance

HUD’s Office of Public and Indian Housing (PIH) issued Notice PIH 2017-07 to provide public housing agencies (PHAs) guidance regarding potential eligibility for Housing Choice Voucher (HCV) shortfall funding in calendar year 2017. Shortfall funding would have to be provided by Congress either through a full-year FY17 Continuing Resolution (CR) or appropriation. The Notice also provides instructions for PHAs identified to be at risk of a HCV funding shortfall.

The Notice states that based on possible funding scenarios if a full-year CR is enacted, or if an appropriations act is enacted at either the House- or Senate-proposed levels, HUD anticipates a deeper housing assistance payment (HAP) proration than previously experienced. To arrive at proration, HUD determines the total voucher eligibility for all PHAs and compares that amount to the total available HAP renewal funding provided by a funding appropriation. This proration factor is then applied to each PHA’s calendar year eligibility. A proration of less than 100% is applied if the nationwide eligibility exceeds the available HAP renewal funding provided by Congress. The 2016 proration was 95%.

HUD writes that local HUD Field Offices (FO) and PIH’s Shortfall Prevention Team (SPT) are currently identifying PHAs at risk of a shortfall based on specific criteria and estimated HAP proration levels. For PHAs identified as having a potential shortfall, the Notice specifies four actions that PHAs must take when instructed to do so by the SPT.

For instance, the Houston Housing Authority (HHA) received a letter on April 21 regarding a projected $9 million HAP funding shortfall. HUD’s letter to HHA stated that the PHA is “expected to take every possible action to reduce costs to prevent the termination of HCV participants due to insufficient funds.” The letter requires the four immediate actions listed in Notice PIH 2017-07:

  1. Cease issuing vouchers to applicants. However, this does not apply to:
    • Families who are HCV participants and are issued a voucher to move to a different unit;
    • Tenant protection vouchers that are being issued to families residing in a covered property at the time of an eligibility event; or
    • HUD-VASH vouchers up to the baseline level of units under all HUD-VASH allocations (not just recent allocations), including turnover of HUD-VASH vouchers.
  2. Rescind any unused vouchers that were issued to applicant families and cease leasing those rescinded vouchers, unless the applicant family has turned in a Request for Tenancy Approval and the unit has passed inspection. (This does not apply to vouchers that were issued for project-based voucher [PBV] HAP contracts for units that were under an agreement to enter a HAP as of the application date.)
  3. Cease absorbing portable vouchers, and do not allow current HCV participants to port to higher cost areas or voluntarily move to higher cost units within the agency’s jurisdiction. Involuntary moves (for example, if the landlord won’t renew the lease) and moves needed as a reasonable accommodation for families with a disabled family member should still be allowed.
  4. Do not issue vouchers to a family who wants to voluntarily move from a PBV unit with tenant-based assistance. However, if a unit becomes vacant, the PBV unit shall be filled with a family from the waiting list.

According to an article in the Houston Chronicle, HHA plans to rescind vouchers already provided to 900 households whose chosen homes have yet to pass inspection and will keep 28,000 households on its waiting list.

Notice PIH 2017-07 is at: http://bit.ly/2oO1pdB

HUD’s April 21, 2017 letter to the Houston Housing Authority is at: http://bit.ly/2oR1YEg

The April 26, 2017 Houston Chronicle article is at: http://bit.ly/2qkwir9