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HUDBlast July 10, 2006 |
New Special Claims Guide Released
The Office of Management & Budget (OMB) has approved the Special Claims Processing Guide and HUD has released the new guide to the industry. This new guide replaces all previous editions. The new Special Claims Guide can be found on www.hudclips.org under “What’s New” or can be accessed through the HUDClips Library.
HUD has been working on the new guide for years and recently released a draft of the guide to solicit comments from project-based Section 8 industry stakeholders. Many stakeholder comments were incorporated in the guide. Questions regarding the Special Claims Guide can be directed to the Special Claims Mailbox at Special_Claims_Comment_Box@hud.gov The guide is effective for all special claims submitted on or after August 1, 2006. The Enterprise Income Verification (EIV) System
The Department believes EIV is a critical tool to ensure that the right benefits go to the right persons. EIV is a wage and benefit tool provided through HUD’s secure internet system that currently allows public housing agencies (PHAs) and will soon allow multifamily owners and agents (O/As) to verify tenant-reported income from an independent source during mandatory tenant re-certifications. O/As and PHAs are expected to use the data available through EIV to help the Department reduce errors in subsidy payments.
Current Status
O/As as well as PHAs have been using the Tenant Assessment Subsystem (TASS) to verify tenant Social Security (SS) and Supplemental Security Income (SSI) benefit payments provided by the Social Security Administration (SSA).
The first step in transitioning from TASS to EIV took place in March 2006, when the TASS functionality was integrated into EIV, meaning the SS/SSI benefit data HUD receives from SSA is now also contained in EIV for verification purposes. Since then, TASS has been operating in parallel with the TASS functionality in EIV. TASS will continue operating in parallel with the TASS functionality in EIV until September 22, 2006; after which TASS will no longer be available.
Beginning on September 25, 2006, O/As and PHAs will obtain SS/SSI benefit verification information only through EIV. It is also intended that, as of September 25, 2006, O/As will join PHAs in being able to obtain through EIV, the Department of Health and Human Services’ National Directory of New Hires (NDNH) data such as family new hire information, wage, and unemployment insurance benefit data that comes from State Wage Information Collection Agencies (SWICAs).
Important Dates
March 2006 TASS functionality integrated into EIV.
June 6, 2006 Although after this date no new tenant certification data will be posted in TASS for PHA households, O/As will be able to access June 2006, July 2006, August 2006, September 2006 and October 2006 recertification data for tenants under their portfolio. (PHAs acting as contract administrators also will be able to access tenant data for their assigned projects and contracts.) The tenant data will be refreshed each month until September 22, 2006.
July – Sept 2006 O/As obtain system access rights through the Multifamily Housing (MF) Help Desk for access to EIV.
Sept 22, 2006 According to REAC, access to TASS will be terminated.
Sept 25, 2006 Access to SS/SSI data from SSA through EIV and potentially NDNH data for O/As through EIV.
Instructions for Accessing EIV for O/As
The MF Housing Help Desk will be authorized to provide O/As with system access rights to EIV and will be the primary contact for EIV support. It is anticipated that this process will begin in July 2006.
Until the enhancements to the existing contract for the MF Housing Help Desk are approved, please do not contact the MF Housing Help Desk for EIV support. In addition, please do not contact the EIV Help Desk for EIV support at this time.
A message will be posted to the TRACS, TASS, PIH EIV, and Multifamily Housing Programs RHIIP web pages and a notice will be sent through TRACSmail as soon as the Multifamily Housing EIV Help Desk support function is authorized. This message will also include information on when EIV data will be available to O/As and the instructions for gaining access to such data. More information will follow. PRAC Increases
In Notice H 06-06, HUD announced a Reinstatement of Policy Permitting Increases of Project Rental Assistance Contract (PRAC) Reservations Prior to Occupancy Under the Section 202 and the Section 811 programs.
Specifically, Notice H 06-06 revises the instructions in a previous notice (H 96-102) to the extent necessary to provide for HUD’s consideration and approval of PRAC increases prior to execution of the PRAC contract (Italics added). HUD explained its change in policy as follows:
“Based on feedback from our clients, program stakeholders and HUD Field Office staff, the policy prohibiting PRAC increases until after one full year of project operation has created serious financial hardships for Section 202 and Section 811 project sponsor/owners during the first year of project operation. Because it was not the intent of the Department to place Section 202 and Section 811 projects in financial harm, the Department is rescinding the instructions in Section 1.L., Section 5.D., and Section 7.B.2 of Notice H 96-102 that provides the instructions to carry out the prohibition of increases in PRAC reservations before the first full year of project operation and is hereby reinstating the previous policy for considering and approving PRAC increases prior to execution of the PRAC.”
For more information, please see www.hudclips.org
Emergency Capital Repair
Grants for Multifamily Housing Projects Designated for Occupancy by the Elderly.
On May 22, 2006, a notice was published in the Federal Register regarding “Emergency Capital Repair Grants for Multifamily Housing Projects Designated for Occupancy by the Elderly”. This notice announces the availability of approximately $30 million in grant funds to make emergency capital repairs to eligible multifamily projects owned by private nonprofit entities that are designated for occupancy by elderly tenants.
The capital repair
needs must relate to items that present an immediate threat to the health,
multifamily projects owned by private nonprofit entities that are designated for
occupancy by elderly tenants. The capital repair needs must relate to items that
present an immediate threat to the health, safety, and quality of life of the
tenants. The intent of these grants is to provide one-time assistance for
emergency items that could not be absorbed within the project's operating budget
and other project resources, and where the tenants' continued occupancy in the
immediate near future would be jeopardized by a delay in initiating the proposed
cure. Implementation of New Rules Pertaining to the Violence Against Women Act
HUD Released Notice: PIH 2006-23 on June 23, 2006. This notice describes requirements for implementation of the Violence Against Women and Justice Department Reauthorization Act 2005. The notice can be found on the HUDClips web site at www.hudclips.org .
Among many other things of significance to PHAs, VAWA prohibits the eviction of, and removal of assistance from, certain persons living in public or Section 8-assisted housing if the asserted grounds for such action is an instance of domestic violence, dating violence, sexual assault, or stalking, as those terms are defined in Section 3 of the United States Housing Act of 1937 as amended by VAWA (42 U.S.C. 13925).
PHAs administering the Public Housing, Section 8 Voucher programs, including the HCV program and all owners participating in the Section 8 voucher and project-based programs must comply with this law. Accordingly, PHAs should make tenants participating in all public housing and voucher programs as well as owners participating in the Section 8 voucher programs aware of the requirements of VAWA as soon as possible.
HUD is developing proposed regulations that make conforming changes in existing regulations and provide guidance regarding the requirements of this law. In the interim, PHAs should be mindful that these statutory provisions were effective the date the law was enacted (January 5, 2006).
Also, because Section 606 of VAWA requires the issuance of a “HUD approved certification form” for victims of abuse to use in the event that a PHA or Section 8 owner requests (as they may under the Act) that a victim of abuse certify that the alleged incidents of abuse are bona fide, PIH is developing such a form, and additional information about the form will be forthcoming. In the interim, PHAs, owners, and managers are encouraged to accept other types of certifications from alleged victims.
PHAs, owners, and managers are encouraged to access VAWA 2005 via the Internet at the following Website addresses: http://www.gpoaccess.gov/plaws/index.html or http://thomas.loc.gov/bss/d109/d109laws.html and search for Public Law 109-162 to access the text of the final law. RHIIP Listserv
RBD encourages our customers to sign up for HUD’s RHIIP Listserv. Not only will this valuable tool provide your property management professionals with information about the latest multi-family housing announcements, but the Listserv regularly provides tips and clarifications regarding day-to-day operations.
In addition, you can indicate your participation on two segments of the Management & Occupancy Review. The RHIIP Listserv provides continuing education and demonstrates dedication to keeping abreast of regulatory changes. This, of course, improves your ability to implement changes in policy and procedure.
Sign up today at http://www.hud.gov/subscribe/mailinglist.cfm. Scroll down to the Multifamily Housing RHIIP (Rental Housing Integrity Improvement Program) Tips. Click on that option and sign up!! |
