HUD’s Offices of Multifamily Housing Programs (Multifamily) and Public and Indian Housing (PIH) recently posted updated coronavirus-related guidance.
Specifically, PIH posted an update to its Frequently Asked Questions (FAQs) pertaining to the Centers for Disease Control and Prevention (CDC) eviction moratorium on January 8, reflecting that the date the moratorium is in effect was extended to January 31, 2021. The new date is the only change for three of the FAQs, EM-CDC 1, EM-CDC 14, and EM-CDC 15.
Multifamily, which oversees contracts with private owners of HUD-assisted properties, issued its ninth update to “Questions and Answers for Office of Multifamily Housing Stakeholders: Coronavirus (COVID-19)” on January 4. The previous update was on October 14, 2020 (see Memo, 10/26/20). The latest version updates eight questions, with six of them simply extending the time the guidance applies to May 31, 2021. There are three new questions, two of which are most relevant to residents and advocates.
Under the category of “Resident Health,” Q15 (page 7) states that Multifamily-assisted properties may allow providers of healthcare services to temporarily use property common areas, parking lots, and vacant offices to provide flu shots, COVID-19 testing, and vaccines to residents. The services must not affect property operating costs beyond budgeted and approved supportive services funds. Owners and agents should ensure that their testing site has a Clinical Laboratory Improvement Amendments (CLIA) certificate of waiver or is covered by another facility’s CLIA certificate.
Under the category of “Asset Management”/“Property Reviews, Inspections, and Rent Comparability Studies,” Q4 (page 23) states that HUD will not waive the requirement for an owner to perform annual Management Occupancy Review (MOR) unit inspections. HUD Handbook 4350.3, REV-1, paragraph 6-29.A.3, requires owners to perform unit inspections at least annually to determine whether appliances and equipment in a unit are functioning properly and to assess whether a component needs to be repaired or replaced. If local or state health department coronavirus guidance prevents owners from entering a unit, an owner should consult with a tenant to confirm whether there are any issues with appliances, equipment, or other components in their unit and document the tenant’s report. Owners may also consider using electronic means to perform remote or virtual unit inspections and as a means of submitting work orders to minimize in-person interactions during the pandemic, when possible.
The Multifamily January 4, 2021 update is at: https://bit.ly/38BR5zm
The PIH January 8, 2021 update is at: https://bit.ly/3i8GD5B
More about Project-Based Rental Assistance is on page 4-46 of NLIHC’s 2020 Advocates’ Guide.
More about Public Housing is on page 4-30 of NLIHC’s 2020 Advocates’ Guide.
More about Housing Choice Vouchers is on page 4-1 of NLIHC’s 2020 Advocates’ Guide.