HUD’s Office of Multifamily Housing (Multifamily) issued Notice H 2022-06 announcing the continued availability of $148 million in COVID-19 Supplemental Payments (CSP) funds for privately owned properties assisted by the following programs: Project-Based Section 8 and Section 236, Section 202 Supportive Housing for the Elderly, and Section 811 Supportive Housing for Persons with Disabilities. The funds are what remain of the $1 billion provided by the CARES Act, and the announcement marks the final opportunity for owners to request CSP funds.
The Notice establishes a fifth request window (Round V) and updates property owner submission requirements. Approximately $139 million will be available for Section 8 Project-Based Rental Assistance properties, $2 million for Section 202 properties, and $8 million for Section 811 properties. Core eligibility criteria and the process for awarding funds are unchanged from Notice 2021-05 (see Memo, 9/27/21). The Notice incorporates clarifications provided in the Frequently Asked Questions issued in October 2021 (see Memo, 10/18/21) and expands a discussion of allowable expenses.
Notable changes regarding eligible operating expenses include the following:
- Expenses can include staff or contract costs to conduct training for residents on the use of technology and “virtual” services that further social distancing goals. These costs may include training on using desktop or mobile devices to aid in completing income recertifications, making online maintenance requests, using social media to maintain community connections, and accessing telehealth or other supportive services through an online interface.
- Office technology and other equipment to facilitate social distancing may now include one device per 100 households for use by tenants in support of property operations (i.e., for completion of recertifications and submitting maintenance requests).
- To maintain or enhance ongoing service coordination in properties designated to serve elderly people or people with disabilities, CSP may now include one IT device per property or per every 50 residents for other program use.
Notable changes regarding eligible capital expenses include the following:
- To secure reimbursement for emergency generators to protect vulnerable elderly residents from the exposure risk associated with evacuations/displacement, it is now sufficient that a property be designated as an elderly project. If a property does not have this designation, it may also qualify if at least 50% of the units are occupied by elderly people, and – for the first time – physically disabled households. As before, Multifamily will allow reimbursement only where generators are necessary to address critical medical needs and a documented risk that recurring power outages pose a significant risk to residents should public health directives prevent or discourage temporary relocations. Notice H 2022-06 adds that a property must also demonstrate power outage risk in one of two ways.
- Capital expense can now include the incremental cost of adding enhanced “air scrubbers” that are targeted to building common areas.
- Costs to improve or establish outdoor seating areas that permit socializing with a decreased risk of virus transmission, relative to indoor gatherings, are now eligible expenses. These expenses may include the purchase of chairs, benches, tables, umbrellas, tents, shade canopies, and pathway or security lighting. Seating area coverings must not permanently attach to buildings, and installation must not involve site excavation, such as for deep post holes or new concrete foundations.
The latest round of CSP funding will allow owners to submit applications for reimbursement of eligible expenses incurred for the four previously announced operating periods (from March 27, 2020, through October 31, 2021) and the new operating period (from November 1, 2021, through January 31, 2023). The deadline to submit applications is February 21, 2023.
Read Notice H 2022-06 at: https://bit.ly/3U3X2dw
Read about the Project-Based Section 8 program on page 4-67 of NLIHC’s 2022 Advocates’ Guide.
Read about the Section 202 Supportive Housing for the Elderly program on page 4-73 of NLIHC’s 2022 Advocates’ Guide.
Read about the Section 811 Supportive Housing for Persons with Disabilities program on page 4-78 of NLIHC’s 2022 Advocates’ Guide.