**Special Attention of Notice** PIH 2008-9 (HA)

Public Housing Agencies administering Housing

Choice Voucher Programs

Public Housing Hub Office Directors Issued: January 30, 2008

Public Housing Program Center Directors

Regional and Field Office Directors Expires: January 31, 2009

Financial Management Center

State and Area Coordinators

Cross Reference: PIH Notice 2006-3

PIH Notice 2006-5

**Subject: Financial Reporting Requirements for the Housing Choice
Voucher Program Submitted through the Financial Assessment Subsystem for
Public Housing and the Voucher Management System.**

1.  **[Purpose.]{.underline}**

> The Uniform Financial Reporting Standards (UFRS), at 24 C.F.R. §
> 5.801, require Public Housing Agencies (PHAs) or any other
> entities[^1], such as non-profit organizations or cities that
> administer the Housing Choice Voucher (HCV) Program, to submit
> financial information to the Department of Housing and Urban
> Development (HUD) electronically. With the issuance of Notice PIH
> 2006-3 on January 11, 2006, PHAs were reminded of the regulatory
> requirement to submit their fiscal year end (FYE) financial
> information to HUD through the Financial Assessment Subsystem for
> Public Housing (FASS-PH), and to submit certain leasing and cost data
> through the Voucher Management System (VMS). For some PHAs, this
> constituted their first year of providing annual financial reports to
> HUD through FASS-PH. During HUD's review of these submissions, certain
> common reporting issues were noted.
>
> This letter clarifies the financial reporting requirements and
> deadlines for those PHAs that administer the HCV and HCV related
> programs (Disaster Voucher Program (DVP), Katrina Disaster Housing
> Assistance Program (KDHAP), Moderate Rehabilitation (Mod Rehab) and
> Mainstream 5-Year program (MS5), if applicable).

2.  **[Background.]{.underline}**

> Under UFRS, PHAs are required to submit their financial data
> electronically as required by HUD. Notice PIH 2006-3 required PHAs
> administering the HCV program to submit their Annual Financial
> Statements through FASS-PH and their monthly/quarterly leasing and
> cost data through VMS. Failure to do so by the HUD required deadlines
> may result in a penalty on a PHA's monthly administrative fees.

3.  **[Program and "Entity-wide" Reporting Requirements.]{.underline}**

> The FASS-PH system was developed under an "entity-wide" concept; that
> is, PHAs report all the programs and activities that constitute the
> PHA as defined by Generally Accepted Accounting Principles (GAAP) as
> promulgated by the Government Accounting Standards Board (GASB). Under
> this concept, HUD is generally able to gain a higher level of
> assurance on the financial data as it is directly comparable to the
> audit. However, for a number of
>
> Section 8 Only PHAs, this requirement is not practical and does not
> provide HUD the usual level of assurance, therefore alternate
> reporting procedures will be used for these cases. Regardless of the
> information submitted to HUD under UFRS for this monitoring purpose,
> Section 8 Only PHAs remain subject to the audit and filing
> requirements under the Single Audit Act and OMB Circular A-133 --
> *Audits of States, Local Governments, and Non-Profit Organizations*,
> where applicable.
>
> [FASS-PH reporting requirements under UFRS]{.underline}

-   *Section 8 Only PHAs as a Stand Alone Reporting Entity (Primary
    Government).* For those Section 8 Only PHAs that are defined by GAAP
    as a primary government or component unit that will have its own
    financial audit, the PHA will report[^2] all of its financial
    activities (entity-wide).

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-   Section 8 Only PHAs that are part of a Nonprofit Agency. For Section
    8 Only PHAs that are organized as part of a nonprofit agency that is
    mostly non-housing related or part of a larger non-general purpose
    governmental agency (such as a state housing finance agency or state
    development authority), and whose HCV and related activities
    (including housing assistance payments) constitute less than 50% of
    that entity's activities, the PHA should report^2^ only the HCV and
    HCV related programs (DVP, KDHAP, Mod Rehab, and MS5 program, if
    applicable) and other UFRS required programs. Activity is defined
    for this purpose as total operational expense and capitalized costs
    incurred during the current reporting period.

-   Section 8 Only PHAs that are part of a Larger General Purpose
    Government. For those Section 8 Only PHAs that are part of a larger
    general purpose government (e.g., program, division, or department
    within a municipality or state), the PHA should report^2^ only the
    HCV related and other UFRS required programs as noted under the
    Nonprofit Agency section above. It is recommended that this general
    purpose government declare the HCV related programs as a major
    "enterprise" fund.

> For those HCV related programs that are accounted for as part of a
> general purpose government's General or Special Revenue fund(s), the
> entity may submit to FASS-PH using modified accrual.

4.  **[Financial and Compliance Procedures.]{.underline}**

> For those general purpose governments and non-profits that have not
> declared their HCV related programs as a major fund for financial
> statement purposes or as a major program under OMB Circular A-133, the
> audit obtained may not be sufficient for HUD to properly monitor its
> financial and compliance interest in these entities. Therefore, in
> order for HUD to gain an acceptable level of assurance, these PHAs may
> be directed to procure Independent Public Accountant (IPA) services
> for financial and compliance procedures as specified by the Department
> (auditor agreed upon procedures). These PHAs should contact PIH
> Financial Management Division (FMD) at
> PIH_Financial_Management_Division@hud.gov in order to confirm the need
> to undertake such an IPA service. If the Department determines that
> IPA services must be performed, the Department will reimburse the
> agency for this cost.

5.  **[Financial Data Schedule (FDS) as Supplementary
    Information.]{.underline}**

> The FDS is prepared as supplementary information to the financial
> statements, produced in hard copy (normally as part of the annual
> financial report but may be issued separately), and reported on by the
> auditor, regardless of whether the FDS is entity-wide[^3]. The FDS is
> essentially a trial balance of the financial statements, currently
> arranged by Catalogue of Federal Domestic Assistance (CFDA) number. If
> the supplementary information has not been subjected to the auditing
> procedures applied in the audit of the basic financial statements, the
> auditor would express no "in relation to" opinion on this schedule,
> but the report and FDS should still be issued as supplementary
> information.

6.  **[Fiscal Year End Reporting.]{.underline}**

> PHAs submit to FASS-PH based on their FYE. For some PHAs that are part
> of a larger government or non-profit, the FYE recorded in the Public
> and Indian Housing Information Center (PIC) is different than the FYE
> of the primary government or nonprofit agency under which the PHA is
> organized. For these Section 8 Only PHAs, the PHA should report its
> year end financial data to FASS-PH based on the primary government or
> nonprofit agency's FYE.

-   For these PHAs, as described under this section (6. Fiscal Year End
    Reporting) the PHA should request an update to its HCV FYE in PIC to
    coincide with that of the primary government or nonprofit agency.
    The PHA has until 03/31/08 to request such change. If the PHA does
    not request such an update, HUD will update PIC on its own schedule.
    The PHA should contact the Real Estate Assessment Center (REAC) at
    <REACSection8Assessment@hud.gov> to notify FASS-PH of its intent to
    update its FYE and then follow the instructions in a forthcoming PIH
    Notice that will provide the steps necessary to complete a FYE
    update in PIC or to notify FASS-PH of its intent to complete the
    additional financial and compliance procedures as outlined by the
    Department (see the next bullet).

-   Until the update in PIC is complete, the PHA will file its unaudited
    submission based on its current PIC FYE. To fulfill the audited
    submission as required under UFRS, the PHA may request a waiver for
    additional time to coincide its audit submission with that of the
    primary government, or the PHA will need to procure IPA services for
    financial and compliance procedures as outlined by the Department
    (auditor agreed upon procedures) if the PHA's HCV related programs
    are over the A-133 Audit Threshold. PHAs should first contact the
    FMD at PIH_Financial_Management_Division@hud.gov to determine the
    appropriate reporting mechanism. If the need to procure IPA services
    is approved, the Department will reimburse the agency for this
    additional cost.

-   In lieu of updating their FYEs, these PHAs may elect to have IPA
    services for financial and compliance procedures as outlined by the
    Department completed on their HCV related programs, based on their
    current recorded FYEs in PIC. PHAs that elect this method need not
    contact HUD, but are required to submit their information based on
    FYE as reported in PIC. The additional cost will not be reimbursed
    by the Department.

-   If the FYE of the primary government does not end on a quarter, the
    PHA should not change its FYE and may need to procure IPA services
    for financial and compliance procedures as outlined by the
    Department (auditor agreed upon procedures). PHAs should first
    contact the FMD at PIH_Financial_Management_Division@hud.gov in
    order to receive confirmation this work is required. If the need to
    procure IPA services is required, the Department will reimburse the
    agency for this additional cost.

7.  **[FDS Submission Deadlines.]{.underline}**

> Unaudited submissions are due no later than 2 months after the PHA's
> FYE; for those entities required to have an audit, the submissions are
> due 9 months after the PHA's FYE. PHAs are required to submit their
> financial information through the FASS-PH system. PIH Notice 2006-3,
> issued January 11, 2006, reaffirmed this requirement.
>
> The table below illustrates the common PHA FYEs and associated dates
> that the annual unaudited and audited submissions are due. For
> example, a PHA with a March 31 (3/31) FYE needs to submit its
> unaudited submission to HUD no later than May 31, and its audited
> submission no later than December 31 (12/31).

# Financial Reporting Schedule Due Dates

+---------------------+-----------+-----------+-----------+-----------+
| # Fiscal Year End   | # 12/31   | # 03/31   | # 06/30   | # 09/30   |
+---------------------+-----------+-----------+-----------+-----------+
| # U                 | # 02/28   | # 05/31   | # 08/31   | # 11/30   |
| naudited Submission |           |           |           |           |
+---------------------+-----------+-----------+-----------+-----------+
| #                   | # 09/30   | # 12/31   | # 03/31   | # 06/30   |
|  Audited Submission |           |           |           |           |
+---------------------+-----------+-----------+-----------+-----------+

8.  **[FASS Waiver and Extension Requests.]{.underline}**

> PHAs that need extra time to make their submissions may request a
> waiver or extension from HUD. Requests for both waivers and extensions
> need to be made, and will be approved or denied by HUD, prior to the
> respective due dates. For circumstances beyond the PHA's control,
> approval of either the extension or waiver defers the normal due date
> of the financial data. An example of a circumstance beyond a PHA's
> control is a natural disaster that results in significant destruction
> to a PHA's properties, computer systems, or data, thereby impeding the
> PHA's ability to submit data on time.
>
> If an extension or waiver is not granted, the PHA may be sanctioned as
> described in Section 11 of this Notice. This sanction will be applied
> for submissions beginning with March 31, 2008, FYE submissions.

-   *Extension Requests.* An extension request is used by a PHA to
    request additional time to submit its **unaudited** submission. The
    PHA request, as well as HUD's decision to grant an extension, is
    performed electronically on-line through a link in the FASS-PH
    system. Paper, fax, or phone requests will not be accepted.

> To request an extension, PHAs need to log into the FASS-PH system
> normally prior to the reporting deadline. From the inbox, a PHA will
> need to enter its PHA code and reporting date, select "Unusual
> Circumstance Request" from the submission-type dropdown text box, and
> click "Go." The PHA should then select the "Unusual Circumstance
> Request" link that will appear and provide the information requested
> on the screen, which is primarily the number of days requested for the
> extension and an explanation of the circumstances surrounding the need
> for an extension. The PHA must select the "submit" button to complete
> its request.
>
> HUD's disposition of the request and the length of the extension will
> be reflected in this area of the system once HUD has made its
> determination. The PHA should periodically check this link to find the
> results of its request. PIH's REAC is responsible for the approval or
> denial of all extension requests and the processing of these requests.
> The field office or other PIH offices are not normally part of the
> extension process.
>
> Section 9, of Chapter 5b of the current Public Housing Agency and
> Auditor User Guide details this process. This guide can be found at:
> <http://www.hud.gov/offices/reac/products/fass/pha_doc.cfm>.

-   *Waiver Requests.* A waiver request is used to request additional
    time to make an **audited** submission. The PHA must submit a hard
    copy of the request to HUD that conforms to the following
    requirements:

1.  There must be a written request (i.e., letter) to HUD to waive the
    audited due date, along with an explanation of the circumstances
    surrounding the need for additional time.

2.  Documentation that supports the circumstances surrounding the waiver
    request must be included. If the PHA is requesting additional time
    to submit the audited submission because of an Independent Public
    Accountant's (IPA) inability to complete the audit on time, the PHA
    must submit a copy of the engagement letter documenting when the
    auditor was hired and the scheduled completion time of the audit.

3.  The request and supporting documentation must be mailed to both the
    PHA's assigned Field Office and to:

> U.S. Department of HUD
>
> Office of Public and Indian Housing - Real Estate Assessment Center
>
> Attention: -- Deputy Assistant Secretary
>
> 550 12^th^ Street, SW, Suite 100
>
> Washington, DC 20410
>
> Based on a review of the request, PIH REAC will provide a
> recommendation to the Assistant Secretary of PIH on whether to approve
> or deny a waiver request and is responsible for the processing of all
> waiver requests.  However, the Assistant Secretary of PIH will make
> the determination on whether to approve or deny the waiver request. 
> The field office or other PIH offices are not part of the waiver
> process. If the waiver request is approved, HUD will notify the PHA by
> mail. It is highly recommended that PHAs mail their requests for
> waiver 60 days prior to the audited submission date. REAC provides
> further waiver guidance at:
> <http://www.hud.gov/utilities/intercept.cfm?/offices/reac/products/PDFs/waiver_v8_for_pvcs.pdf>.
>
> Waiver requests must be received prior to the submission due date in
> order to be considered.

9.  **[VMS Submissions.]{.underline}**

> PHAs are required to transmit certain leasing and cost data
> electronically through VMS.  In calendar years 2005 and 2007, VMS data
> was used to determine the renewal funding levels. The Department also
> uses VMS data for other funding decisions, monitoring, and
> funding-related factors under the Section Eight Management Assessment
> Program (SEMAP).  Therefore, it is imperative that PHAs comply with
> reporting requirements and timelines for reporting through VMS,
> ensuring that the information submitted is both timely and accurate. 
> The data provided in VMS is always subject to verification and review
> by HUD's Quality Assurance Division.
>
> Data submissions are currently collected quarterly.  Although PHAs may
> enter VMS information at any time, the designated quarterly submission
> period begins 15 days following the last date of the quarter and ends
> on the last day in that month.

# VMS Reporting Schedule Due Dates

+---------------------+-----------+-----------+-----------+-----------+
| # Quarter End Date  | # 12/31   | # 03/31   | # 06/30   | # 09/30   |
+---------------------+-----------+-----------+-----------+-----------+
| #                   | # 01/31   | # 04/30   | # 7/31    | # 10/31   |
| Submission Due Date |           |           |           |           |
+---------------------+-----------+-----------+-----------+-----------+

> Because VMS data reporting is time sensitive, requests to extend
> submission deadlines cannot be entertained.  However, PHAs that are
> not be able to meet reporting deadlines due to circumstances beyond
> their control (i.e. natural disasters) should notify the FMC at
> <Financial_Management_Center@hud.gov>.  PHAs that do not submit the
> required data by the reporting deadline will be sanctioned as
> described in Section 11 of this Notice.  This sanction will be applied
> for non-submissions beginning with the April 30, 2008 due date for
> submissions.

10. **[HCV Related Programs.]{.underline}**

> Mainstream 5-Year Programs, Mod Rehab, DVP, and KDHAP are funded
> separately from the HCV program. The general HCV program activities
> are reported under CFDA 14.871 in FDS. For FDS reporting, MS5
> activities are reported as a separate program under CFDA 14.181
> Supportive Housing for Persons with Disabilities. Mod Rehab activities
> are reported under CFDA 14.856. The DVP activities are reported under
> CFDA 14.DVP. These programs should not be combined or reported with
> the HCV Program. Since there is not a separate CFDA number for
> reporting KDHAP activities, KDHAP should be reported under Other
> Federal Programs. As noted in section 3 of this notice, PHAs that are
> stand alone reporting entities will report all of their financial
> activity to HUD, while all other PHAs will report on their HCV related
> programs as defined in this notice along with any other program (for
> example substantial rehabilitation) as required by UFRS.
>
> PHAs must report Mainstream 5-Year, DVP, and KDHAP activities in the
> VMS. Specifically, the dollar amount of HAP payments and the number of
> vouchers utilized must be reported. Mod Rehab is not reported in VMS.

11. **[Sanctions.]{.underline}**

> 24 CFR 982.152(d) allows the Department to sanction a PHA by reducing
> a PHA's administrative fee if a PHA fails to perform its
> administrative responsibilities correctly, such as reporting
> noncompliance and/or VMS non-submission. The sanction will be
> calculated beginning the first day of the month following the
> submission closing due date. The monthly penalty will continue until
> such time as the PHA complies with the reporting requirements or a
> waiver is granted.  The imposition of such penalties will be
> communicated under separate cover and represents a permanent reduction
> in funding for administrative fees for the current calendar year that
> shall not be reversed. However, this will not impact the baseline
> administrative fee calculations.
>
> Under FASS-PH reporting for a PHA's unaudited submission any
> associated sanction for reporting noncompliance will not begin until
> the 16^th^ day of the 3^rd^ month following the end of their fiscal
> year.

12. **[Clarifications for FASS-PH Reporting.]{.underline}**

> PHAs are required to report their financial information to the
> Department using GAAP. PIH Notice 2006-3(HA) states that effective
> January 1, 2005, excess budget authority disbursed to PHAs that is not
> utilized to pay housing assistance payments (HAP) or administrative
> costs would become part of the undesignated fund balance. However,
> most PHAs utilize a single purpose proprietary fund reporting model.
> The concept of fund balance does not apply under GAAP for this model.
>
> This clarifies HUD's reporting position that unused HAP under
> proprietary fund reporting should be reported as *restricted net
> assets* (equity), with the associated cash and investments also being
> reported on the FDS as restricted. Any unused administrative fees
> should be reported as *unrestricted net assets* (equity), with the
> associated assets being reported on the FDS as unrestricted.
>
> Both administrative fee and HAP revenue should be recognized under the
> guidelines set forth in Statement No. 33 of the Governmental
> Accounting Standards Board, "Accounting and Financial Reporting for
> Non-exchange Transactions" (GASB 33). Accordingly, both the time and
> purpose restrictions as defined by GASB 33 are met when these funds
> are available and measurable, not when these funds are expended. The
> HCV program is no longer a cost reimbursement grant, therefore PHAs
> should recognize unspent administrative fee and HAP revenue in their
> reporting period as *revenue* for financial statement reporting, not
> as deferred revenue or as a liability.
>
> Any investment income earned on these funds should be reflected in the
> equity account on which the investment income was earned. For example,
> investment income earned on HAP cash balances should be credited to
> the HAP equity account. Likewise, investment income earned on
> administrative fee cash balances should be credited to the
> administrative fee equity account. The FDS provides specific lines to
> correctly report these transactions. All bank service charges should
> be reflected in the administrative fee equity account.

13. **[Paperwork Reduction Act.]{.underline}**

> The information collection requirements contained in this notice have
> been approved by the Office of Management and Budget (OMB) in
> accordance with the Paperwork Reduction Act of 1995 (44 U.S.C. §§
> 3501-3520), and have been assigned the following OMB control numbers -
> Voucher Management System: 2577-0169; Financial Assessment Subsystem
> 2535-0107. An agency may not conduct or sponsor, and a person is not
> required to respond to, a collection of information unless the
> collection displays a valid control number.
>
> Any questions regarding this notice should be referred to the FMD at
> (202) 708-2934 or emailed to
> PIH_Financial_Management_Division@hud.gov.

Sincerely,

[/s/]{.underline} Paula O. Blunt, General Deputy Assistant Secretary

> for Public and Indian Housing

[^1]: Throughout the remainder of this document the term PHA includes
    these "other entities."

[^2]: Reporting is completed electronically through HUD's Financial
    Assessment Subsystem for Public Housing (FASS-PH).

[^3]: In accordance with Statement on Auditing Standards (SAS) No. 29,
    Reporting on Information Accompanying the Basic Financial Statements
    in Auditor Submitted Documents and Statement on Standards for
    Attestation Engagements (SSAE) No. 10, Attestation Standards:
    Revision and Recodification.