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HUD Office of Multifamily Housing Updates Coronavirus FAQs

HUD’s Office of Multifamily Housing Programs (Multifamily), which oversees contracts with private owners of HUD-assisted properties made updates to its “Questions and Answers for Office of Multifamily Housing Stakeholders: Coronavirus (COVID-19)” (see Memo, 3/16) on March 16.

One notable change was made in the “Policy and Operations” category. Q7 is substantially different, deleting the previous Q8 regarding extensions of time for residents to complete income recertifications. Q7 now explains that an owner may consider extenuating circumstances (including COVID-19 considerations in the community) when the tenant is not available to attend the recertification interview, sign consent forms, or sign form HUD-50059. When an extenuating circumstance is present, there is no change to the tenant’s recertification anniversary date. The Total Tenant Payment/Tenant Rent and the assistance payment are effective retroactively to the recertification anniversary date.

Several notable changes were made in the “Property Reviews and Inspections” category. Q1 states that, until further notice, Multifamily is postponing all Real Estate Assessment Center (REAC) property inspections for all Multifamily-assisted properties. Where there is an exigent circumstance or reason to believe that there is a threat to life or property at a specific location, inspections will be conducted by HUD quality assurance inspectors in compliance with Center for Disease Control and Prevention (CDC) guidelines. Q2 adds that HUD is suspending standard Management Occupancy Reviews (MORs) until a performance-based contract administrator (PBCA) determines that local conditions no longer limit or prevent the PBCA from performing MORs safely.

Q4 indicates that Rent Comparability Studies (RCSs) are suspended in areas that are under a state or nationally declared emergency or where public health officials have imposed limited travel. (RCSs are requested by owners to demonstrate that the rent they wish to charge is comparable to similar, unsubsidized properties in the vicinity. HUD will provisionally accept an owner’s RCS up to 5% above current rent levels, although HUD or the contract administrator (CA) must still review an owner’s RCS to make sure the rent conclusions are reasonable. At the owner’s request, these conclusions can be subject to a new HUD RCS when normal activities resume. On a case-by-case basis, HUD may review and accept higher rents without a HUD RCS at HUD’s discretion.

Finally, under the category “Emergency Preparedness,” HUD adds to Q2, “Capacity-Building Toolkit for including Aging and Disabled Networks” from the U.S. Department of Health and Human Services (HHS).

Advocates should periodically check the Multifamily website for updates. NLIHC will also alert Memo readers and post updates to NLIHC’s COVID-19 webpage.

“Questions and Answers for Office of Multifamily Housing Stakeholders: Coronavirus (COVID-19)” is at: https://bit.ly/392IhPS

NLIHC has a new webpage about coronavirus/COVID-19 and housing and homelessness at: https://bit.ly/2wPKFMA

More information about the Office of Multifamily’s Project-Based Rental Assistance program is on page 4-46 of NLIHC’s 2019 Advocates’ Guide.