On Friday, April 2, 2021, HUD released the Multifamily Q&A for COVID-19 and the CDC Order to Temporarily Halt Evictions Q&A.
We have updated our RBD COVID-19 Resources Page with these new publications.
We're conducting a complete review of the modified and new responses, but we wanted to point out a couple of pieces of GREAT news.
Q16: Are the costs of personal protective equipment (PPE) considered an allowable medical expense for residents?
A: Items intended to reduce the risk of transmitting illness or preventing illness, including personal protective equipment (PPE), can be an eligible medical expense for tenants when it recommended by the CDC. Items such as face coverings, or PPE (e.g., goggles and gloves), are an eligible medical expense if the item was purchased on or after March 27, 2020, and only for the period during which a national, state, or local COVID-19 emergency is in effect.
In addition to being included as current medical expense, eligible families are permitted to include these items as a medical expense retroactive to March 27, 2020 and calculate TTP accordingly. Refer to Handbook 4350.3 paragraph 5-10.D for guidance on the treatment of medical expenses to allow, and subparagraph 6 for guidance on the treatment of one-time nonrecurring medical expenses that have been paid in full. (Added on 4/2/21)
Q27: What emergency funds can owners and agents access for outbreak preparedness and response (including extra supplies, additional administrative hours, staff overtime, and hosting a vaccination site at the property), and what kind of approval do housing providers need from HUD to access the funds?
A: Multifamily property owners and agents can access property operating accounts for all reasonable and necessary COVID-19 related preparedness and response actions, including supplies, PPE, staff hours, overtime, and hosting a vaccination site at the property. Property funds can be used to cover the following types of expenses associated with operating a vaccination site: materials and supplies needed to set up a site (tents, barriers, etc.), and costs related to providing residents with transportation to and from a site. No advance HUD approval is required to access operating account funds.
However, property operating accounts should not be used for purchases of actual vaccines (all COVID-19 vaccines in the United States are currently being purchased by the federal government for administration to recipients without charge to patients or property owners), hiring of medical staff, or other direct medical expenses. To the extent that owner advances are required, owners should receive HUD approval in advance, especially if the owner expects repayment before the distribution of annual (or semi-annual) surplus cash. For those properties with Reserve for Replacement accounts and Residual Receipts accounts, owners can request approval according to current policy and procedures in Handbook 4350.1, Chapter 4 (for Reserve for Replacement) and Chapter 25 (for Residual Receipts), for eligible items. If the owner is seeking to use Reserve for Replacement and Residual Receipt funds for traditionally non-eligible uses, prior approval must be received from HUD field staff and Headquarters, as necessary. (Updated on 4/2/21)
We'll provide a more comprehensive review next week.
