HUD’s Office of Multifamily Housing Programs (Multifamily) posted Notice H 2020-11 on November 24 announcing the continued availability of “COVID-19 Supplemental Payments” (CSP) for Section 8, Section 202, and Section 811 properties to prevent, prepare for, and respond to the coronavirus. The Notice establishes a second request window for property owners to apply for CSP funds to cover expensed incurred between August 1 and November 30. Applications are due December 11.
On July 23, Multifamily issued Notice 2020-08 making up to $190 million available for Section 8 properties, $25 million for Section 202 Housing for the Elderly properties, and $9 million for Section 811 Housing for Persons with Disabilities properties (see Memo, 8/3). Property owners had until August 5 to apply for CSP funds. The supplemental funding is from funds Congress appropriated through the CARES Act, $1 billion for the Project-Based Rental Assistance program (PBRA), $50 million for Section 202, and $15 million for Section 811 (see Memo, 3/30).
A majority of CARES Act funding for Section 8 PBRA (see Memo, 6/8), along with smaller portions of Section 202 and Section 811 CARES Act funding, was used to offset decreased tenant rent payments as tenants experienced reduced or lost income due to the coronavirus pandemic. As a tenant’s income decreases the tenant may request an interim income recertification which lowers the tenant’s rent obligation.
The purpose of CSP is to help owners incurring additional operational costs during the pandemic maintain their properties in decent, safe, and sanitary conditions. The list of eligible expenditures in Notice H 2020-11 is the same as Notice H 2020-08:
- Increased cleaning and disinfecting common areas and property management offices as a preventative measure.
- Intensive deep cleaning and sanitization services in response to the presence of COVID-19 cases at a property, which may include treatment in units being prepared for re-occupancy.
- Office technology and other equipment needs to facilitate social distancing.
- Personal protective equipment (PPE) such as face masks and goggles, gloves, hand hygiene products for use by staff and for residents entering leasing offices or using common areas.
- Facility and equipment related to maintaining adequate social distancing, such as installing cough/sneeze barriers or modifying or limiting access to communal spaces.
- Site control measures to enforce orders to shelter-in-place, stay-at-home orders, or visitor-restriction policies.
- Temporary staffing, contract services, and/or supply expenditures to maintain or improve on-going service coordination in properties designated to serve elderly people or people with disabilities.
- Temporary staffing increases to process higher-than-normal volumes of interim income recertifications requested by tenants due to loss of income.
The notice reiterates that CSP is not a means for owners to receive funding for lower tenant rent contributions due to income reductions, extended vacancies, or unpaid tenant charges.
Multifamily will continue to have two categories of CSP payments, each with separate pools of CSP funds. Tier I Standard Payments will reimburse costs up to a capped amount for both the previous March 27 through July 31 period of Notice H 2020-08 and August 1 through November 30 of the current Notice. The cap is based on a formula that considers property size, whether the property has a service coordinator funded from HUD rent receipts, and whether the property’s rental assistance contract or other controlling documents specify that the property house elderly residents.
Owners may request larger sums under Tier II Exceptional Cost Payments to address cost increases associated with responding to reported COVID-19 outbreaks among property residents or in response to extensive community exposure that creates a greater threat to residents’ health and safety within the property. There is no cap on Tier II payments.
Notice H 2020-11 is at: https://bit.ly/3lyhalW
More information about Project-Based Section 8 is on page 4-61 of NLIHC’s 2020 Advocates’ Guide.
More information about Section 202 Housing for the Elderly is on page 4-67 of NLIHC’s 2020 Advocates’ Guide.
More information about Section 811 Housing for Persons with Disabilities is on page 4-71 of NLIHC’s 2020 Advocates’ Guide.