# Presentation: 675397

## Module 8: New Units

- Calculation and Submission of Operating Subsidy Training

**Notes:**
This module provides an overview of how to report new units added to a PHA’s ACC during the reporting period and up and through the final revision due date on July 15, 2007.  The module will cover adjustments that need to be made to both HUD-52722 and HUD-52723.

## Objectives

- Define New Unit
- Correctly Place New Unit Data on Form HUD-52723
- Understand Implications of New Units on HUD-52722 – (Rolling Base)

**Notes:**
This module has three primary objectives.  First, the module will describe the criteria a unit must meet to be considered “new” and therefore be eligible for operating subsidy.  Second, the module will show the proper way to report new unit data on the HUD-52723.  Most notably, it will show how to report new unit data in Lines 01, 03 and 04 of Section 2.  Finally, the module will show the proper way to report new unit data on HUD-52722.  It will give directions on how to estimate consumption data for partial year data and incorporate that information into the rolling base incentive.

## Definition

- 990.155
- Unit Added to ACC
- Occupied by Eligible Family
- Added During or After Reporting Period

**Notes:**
The discussion and rules regarding new units are described in Subpart B Section 990.155 – Addition and deletion of units.  The Rule states that “to generate a change to its formula amount within each one-year funding period, PHAs shall periodically report” new units during the funding period.  Further, the Rule states that a new unit must meet the following criteria: (1) it must be added to the ACC and (2) be occupied by a family during the reporting or funding period.  

PHAs must consider any new units that come “online” during the reporting period (7/1/2005 to 6/30/2006) and after the reporting period.  
New units coming online during the reporting period will only be partially reported.  Thus, for a PHA to receive full funding for those new units, the difference between reported Unit Months and the total Unit Months for one full year will need to be calculated and reported.  
New units coming online after the reporting period would receive funding for a full 12 months if they were reported prior to the funding period (1/12007 to 12/31/2007) or would receive partial funding if they were to come online during the funding period.  

## New Unit Status

- First Day of Month
- Last Day of Month
- Consistency – Same for Both New Units and Unit Categorization
- Assumed to be Fully Occupied for Funding Period

**Notes:**
As previously discussed in the Unit and Unit Months module, PHAs must decide if they will report units on the first day of the month or last day of the month.  For example, if a PHA has a new unit come online on March 23, 2007, then it may receive funding for the unit for March 2007 or may not receive funding.  If the PHA has chosen the first day of the month to count units, then it would not receive funding for that new unit (i.e. the PHA counted its units on March 1 and that unit was not eligible).  However, if the PHA has chosen the last day of the month to count units, then it would receive funding for that unit.  (i.e. On the 31st of March the unit was eligible.)

A PHA must be consistent in how it counts its units.  If it chooses to use the first day of the month, then it must use the first of the month for both new units and changes in unit status (e.g. a change from vacancy to occupied).  It is in the PHA’s interest to use the last day of the month for new units, however, it may be detrimental to the PHA if a unit becomes vacant during the middle of the month using this reporting method.

Finally, when no data (or only partial data) for new units is reported in the reporting period, it is not known whether or not those units will be vacant or occupied during the funding period.  Thus, the Rule assumes that these new units are occupied and eligible to receive full funding during the funding period.  

## Impact on HUD-52723

- Eligible Unit Months
- Resident Participation
- Asset Management Fee
- IT Fee
- UEL/PEL/Formula Income

**Notes:**
New units will impact HUD-52723 in several ways.  Most importantly, the number of units and eligible unit months reported under Section 2 of the form will increase.  Specifically, the number of unit months reported on Lines 01, 03 and 04 will be impacted.  Other parts of the form that are directly related to EUMs will also change.  This includes the calculation for the Resident Participation, Asset Management Fee and IT Fee add-ons.

As previously discussed in the Add-ons Module, Resident Participation is the product of $25 and the number of EUM reported in Line 16 (Units eligible for funding for resident participation activities) of Section 2.  The Asset Management Fee is the product $4 ($2 for PHAs with less than 250 low-rent units) and the EUM reported in Line 15 (Total Unit Months) of Section 2. The IT Fee is the product of $2 and Total Unit Months reported in Line 15 (Total Unit Months) of Section 2.

Of course, the total dollar value of PEL, UEL and Formula Income, which are reported on a PUM basis, will also be impacted by the additional units.

## Section 2, Lines 01 through 04

| Unit Category | Line | Source |
| --- | --- | --- |
| Occupied Dwelling Units..... | 01 | PHA Provided |
| New Units – Eligible to Receive Subsidy During the Funding Period..... | 03 | PHA Provided |
| New Units – Eligible to Receive Subsidy from 10/1 to 12/31 of Previous Funding Period..... | 04 | PHA Provided
 |

**Notes:**
During the next slides, the module will discuss how new units will impact Line 01 (Occupied dwelling units), Line 03 (New Units Eligible to Receive Subsidy During the Funding Period), and Line 04 (New Units Eligible to Receive Subsidy from 10/1 to 12/31 of the Previous Funding Period).  

It is important to note, Lines 03 and 04 include only data regarding new units.  Line 01 (Occupied dwelling units) includes data from “existing” units and “new” units.  Thus, when discussing new units and Line 01 (Occupied dwelling units), the module is always referring to the new portion of the data in Line 1.

Finally, each of these line items will be provided by the PHA.  The Excel tool (See the Introduction Module) will not auto-populate or calculate these line items.

## Impact on Line 01 – Occupied Dwelling Units

- Occupied Dwelling Units
- Includes Only Partial Year of New Unit Data
- 0 to 12 Unit Months per Unit

**Notes:**
In Line 1 (Occupied dwelling units) the PHA reports dwelling units occupied by a tenant/family.  It is assumed that any new units that have come online during the reporting period will be reported here. The requirement for a PHA to add units states that the unit be on the ACC and be occupied by an eligible family.  However, it is possible that the unit may change categories during the reporting period after it comes online.  In that case, the unit would be reported on lines other than on Line 01.  (Note: In rest of this module it will be assumed that only new unit data is being referred to in Line 01.)

Any new units that have come online during the reporting period will be reported in Line 01 (Occupied dwelling units).  PHAs will not need to make any adjustments to this line.  However, because new units will be eligible for a full year of funding, but Line 01 (Occupied dwelling units) only reports a partial year of data for new units, the information is incomplete.  

PHAs will need to know the number of unit months reported for new units in Line 01 (Occupied dwelling units).  The number of unit months per unit will range from 0 to 12 months.  

Further details on filling out this line will be provided in upcoming slides.

## Impact on Line 03 – New Units

- New Units – Eligible in FY 2007
- Eligible for Funding but Not Reported
- Eligible for 0 to 12 Unit Months per Unit

**Notes:**
Line 03 (New units – eligible to receive subsidy during the funding period...) reports new unit months eligible for funding and not included in Line 01, 02 or 05 to 13 of Section 2.  

As discussed in the previous slide, Line 01 (Occupied dwelling units) is an incomplete estimate of the number of new units to fund.  Either Line 01 (Occupied dwelling units) reports partial year data or no data, but the new unit should be funded for a up to 12 months.  Thus, the reported value for this cell will vary from 0 to 12 unit months per unit.

Further details on filling out this cell will be provided in upcoming slides.

## Impact on Line 04 – New Units

- New Units – Eligible in FY 2006
- Not Included in FY 2006 Funding
- Eligible for 0 to 3 Unit Months per Unit

**Notes:**
New units may come online during a period which results in them not receiving funding even though they were eligible.  This happens when a new unit comes online after the final revision deadline but before the end of the calendar year.  For example, a new unit that comes online on November 1, 2006 is eligible to receive funding for November and December of 2006.  However, the final HUD-52723 will have been submitted by July 15, 2006 (the final revision deadline).  Thus, the PHA would not have been funded for the two unit months in FY 2006.  

Due to recent changes in federal budgeting law, PHAs can only be given operating subsidy for FY 2006 using FY 2006 funds.  FY 2007 funds cannot be used to fund FY 2006 eligibility.  However, there is a loophole, which will allow HUD to fund eligible unit months for the months of October, November and December.  The federal fiscal year runs from October to September, but a PHA is funded on a calendar year basis.  Thus, the months of October, November and December 2006 overlap with the federal fiscal year 2007.  OMB has thus given HUD permission to fund these months using FY 2007 funds if the months were not funded in the previous year.  

The reported value for this cell will vary from zero to three unit months per unit, as funding is only for the months of October, November, and December.

Further details on filling out this cell will be provided in upcoming slides.

## New Unit Categories

- Category #1: Units Added During Reporting Period (7/1/2005 to 6/30/2006)
- Category #2: Units Added After Reporting Period but Before FY 2006 Final Revision (7/1/2006 to 7/15/2006)
- Category #3: Units Added After Reporting Period and After FY 2006 Final Revision in CY 2006 (7/16/2006 to 12/31/2006)
- Category #4: Units Added in Funding Period (1/1/2007 to 7/15/2007)

**Notes:**
As previously discussed, it is possible that a unit will be brought online from the beginning of the reporting period (7/1/2005) until the final revision for FY 2007 (July 15, 2007).  The date during this period that the unit comes online will impact how unit months are calculated and reported.  As such, new units can be categorized by intervals as follows:

Added During the Reporting Period (7/1/2005 to 6/30/2006). These units will be reported in Lines 01 and 03 and receive 12 months of funding.

Added after the reporting period but prior to the final revision due date for FY 2006 (7/1/2006 to 7/15/2006). These units will be reported in Line 03 (New units..) and receive 12 months of funding. Note: The final revision due date may change year to year. 

Added after the final FY 2006 revision due date but in CY 2006.  These units will be reported in Line 03 (New Units...) and Line 04 (New Units...).  These units will receive between 12 and 15 months of funding.

Added in FY 2007 but before the final FY 2007 revision due date.  These units will be reported in Line 03 (New Units...) only.  These units will receive five to 12 months of funding.

## Category #1: Units Added During Reporting Period

**Notes:**
The above chart shows a timeline for Category #1 – Units Added During Reporting Period.  In this example, new units are added on February 18, 2006 and the PHA uses the last day of the month to report unit months.  

The first timeline shows the number of eligible unit months (in red) for the new units during the reporting period.  As shown above the new units are eligible for funding for February, March, April, May and June.

The second timeline (FY 2007 Funding Period) shows the number of unit months reported on Lines 01 and 03 of Section 2.  The five unit months shown in the first timeline are reported in Line 01.  The remaining seven unit months (in green) are reported in Line 03.

Finally, these new units have already been funded for FY 2006 because they came online prior to the final FY 2006 revision due date.  Thus, no units are reported in Line 04 (New units..) as shown in third timeline (FY 2006 Funding Period).   

## Category #2: Units After Reporting PeriodPrior to FY 2006 Final Revision

**Notes:**
The above chart shows a timeline for Category #2 – Units Added After the Reporting Period but prior to the final FY 2006 revision due date.  In this example, new units are added on July 1, 2006 and the PHA uses the last day of the month to report unit months.  

The first timeline shows the number of eligible unit months (in red) for the new units during both the reporting period and final 6 months of FY 2006.  As shown above the new units are not eligible for funding during the reporting period but are eligible during the funding period.

The second timeline (FY 2007 Funding Period) shows the number of unit months reported on Lines 01 and 03 of Section 2. No unit months are reported in Line 01 (Occupied dwelling units).  12 unit months (in green) are reported in Line 03 (New Units...).

Finally, these new units have already been funded for FY 2006 because they came online prior to the final FY 2006 revision due data.  Thus, no units are reported in Line 04 (New Units...) as shown in third timeline (FY 2006 Funding Period).   

## Category #3: Units Added After Reporting Period and After FY 2006 Final Revision

**Notes:**
The above chart shows a timeline for Category #3 – Units Added After the Reporting Period and after the final FY 2006 revision due date.  In this example, new units are added on September 30, 2006 and the PHA uses the last day of the month to report unit months.  

The first timeline shows the number of eligible unit months (in red) for the new units during both the reporting period and final 6 months of FY 2006.  As shown above the new units are not eligible for funding during the reporting period but may be eligible for final four months of FY 2006 and beyond.

The second timeline (FY 2007 Funding Period) shows the number of unit months reported on Lines 01 and 03 of Section 2. No unit months are reported in Line 01.  12 unit months (in green) are reported in Line 03.

Finally, these new units were not funded in FY 2006 because they came online after the final FY 2006 revision due date.  Thus, three units are reported in Line 04 as shown in the third timeline (FY 2006 Funding Period).   

## Category #4: Units Added During Funding Period

**Notes:**
The above chart shows a timeline for Category #4 – Units Added in CY 2007.  In this example, new units are added on April 26, 2007 and the PHA uses the last day of the month to report unit months.  

The first timeline shows the number of eligible unit months (in red) for the new units during the entire period a new unit can be added and still receive funding for FY 2007.  

The second timeline (FY 2007 Funding Period) shows the number of unit months reported on Lines 01 and 03 of Section 2. No unit months are reported in Line 01.  9 unit months (in green) are reported in Line 03.

Finally, these units became eligible in FY 2007 and thus not eligible for funding in FY 2006.  As shown in the final timeline (FY 2006 Funding Period) Line 04 will report zero unit months.

## Impact on HUD-52722

- Need to Annualize New Unit Consumption
- Rolling Base Changes
- Multi-Year Impact

**Notes:**
In addition to impacting HUD-52723, new units will also impact HUD-52722.  Some important points include:

PHAs will not only have to report new units but will also report utility consumption data for those new units (water, electricity, etc.)  
Because new unit data will be included in the current year estimate of consumption for each utility unit but not in prior year rolling base consumption data, adjustments to the rolling base will need to be made.  The methodologies for these adjustments will be discussed in upcoming slides.
Not only will new units impact HUD-52722 in the current fiscal year, but because of the rolling base incentive, they will also will impact HUD-52722 for an additional three years after the initial funding period.  

## Impact on HUD-52722New Unit Revisions

- No Changes to HUD-52722 Due to New Unit Revisions
- New Units Added After Reporting Period do not require update to UEL Calculation
- UEL is PUM Base, Utility Expense Funded through EUM Increase

**Notes:**
New Unit Revisions, which include new unit data submitted after the reporting period, will not be incorporated into HUD-52722.  PHAs will continue to use the UEL as calculated per the original HUD-52722 submission.  

Trying to incorporate revisions after the original submission would be very difficult given the requirements of the rolling base and utility consumption estimates for annualization.   

However, PHAs will still be funded for the utility expenses of those new units in FY 2007.  The added subsidy will result due to the increased EUM count on HUD-52723, which is multiplied by the PUM UEL to estimate total utility expense levels.  

## Section 1 – General Information

- Unit Change Indicator Box

**Notes:**
If new unit consumption data needs to be reported in HUD-52722, then Line 04 – Unit Change Indicator of  Section 1 – General Information must be marked off as yes.

## HUD-52722 Impacted Line Items

| Line Item | Line | Impact by Year |
| --- | --- | --- |
| Actual Consumption.... | 01 | Year 1 to Year 5 |
| Actual Consumption for New Units..... | 07 | Year 1 and Year 2 |
| Annualization of Consumption for New Units | 14 | Year 1 Only
 |
|  |  |  |
| Rolling Base Year 1..... | 02 | Year 2 to 5 |
| Rolling Base Year 2..... | 03 | Year 3 to 5 |
| Rolling Base Year 3..... | 04 | Year 3 to 5
 |

**Notes:**
Several line items on HUD-52722 will be impacted by new units.  This includes:
Line 01 (Actual Consumption), which will impact reporting in the original funding year (Year 1) and the four years thereafter (Years 2 and 5).  
Line 07 (Actual Consumption) for New Units, which will impact reporting in HUD-52722 in Year 1 and Year 2.  
Line 14 (Annualization of Consumptions for New Units) will impact reporting in Year 1 only. 

Each of the rolling base year consumption line items will also be impacted.  These will be impacted in Years 2 to 5.  

## Section 2 – Current Consumption

- Line 1 – Actual Consumption
- Matches Reporting Period (7/1/2005 to 6/30/2006)
- Includes New and Existing Unit Consumption Data

**Notes:**
Consumption data for new units that come online during the reporting period (7/1/2005 to 6/30/2006) needs to be reported in Line 01 (Actual Consumption).  This consumption data is in addition to the consumption data reported for “existing” units.  

Consumption should be reported for the period of time during the reporting period that the new units were eligible.  Thus, if the new units were eligible from May 1, 2006 to June 30, 2006, then utility consumption data should reported for only those two months, even if utility data exists prior to May 1.  

Note: Utility data must be reported for each applicable utility type (i.e. Sewerage and Water, Gas, etc.)

## Section 3 – Rolling Base Consumption

- Line 7 – Actual Consumption for New Units
- New Consumption Data is added to Rolling Base

**Notes:**
Line 7 (Actual Consumption for New Units) is the new unit value reported on Line 01 (Actual Consumption for New Units) during the reporting period.  The amount reported should be less than 12 unit months.  

This line is necessary to add the new unit consumption data to the rolling base.  By adding Line 7 (Actual Consumption for New Units) to Line 6 (Average Rolling Base), the rolling base will now include new unit consumption data in Line 8 (Rolling Base Consumption), which can now be compared directly with Line 1 (Actual Consumption).

Note: Utility data needs to be reported for each applicable utility type (i.e. Sewerage and Water, Gas, etc.)

## Section 6 – Payable Consumption 

- Line 14 – Annualization of Consumption for New Units
- Estimates missing new unit consumption data from reporting period
- Line 7 + Line 14 should equal 12 months of consumption

**Notes:**
Line 14 (Annualization of consumption for new units) is the line where a PHA estimates the expected consumption for new units that were not reported on Line 01 (Actual consumption).  New units are eligible for funding for 12 months if they come online prior to 1/1/2007, however, only partial year consumption data will exist based on the reporting period.

The total value on Line 14 (Annualization of consumption for new units) added to the total value on Line 7 (Actual consumption for new units) should equal 12 months of utility consumption.  

Note: Utility data needs to be reported for each applicable utility type (i.e. Sewerage and Water, Gas, etc.)

To annnualize partial year new unit consumption data, estimates of consumptions must be made.  These estimates shall be determined by using the consumption experience of a project or units with the same utility and likely to have comparable unit levels of consumption based on the physical characteristics of project buildings.  It does not matter if the comparable project or units are owned by the PHA or from another PHA.  The annnualization should take into account differing utility usage based on seasonal differences.  

## HUD-52722 Additional Reporting Requirements

- Consumption Data attached with HUD-52722
- Consumption Estimate Methodology attached with HUD-52722

**Notes:**
In addition to HUD-52722, PHAs will be required to submit supplemental data, showing how the new unit actual and estimated consumption data was calculated or obtained.  For data that needs to be estimated (i.e. Line 14 – Annualization of consumption data), PHAs should provide the methodology and background data used to complete the analysis.  

## Section 3 – Rolling Base Consumption

- Does not include New Unit Utility Consumption Data

**Notes:**
In order to include the rolling base incentive for new units,  new unit consumption data will need to be added to Lines 2 to 4.  However, in the original funding year for new units, new unit consumption data does not exist for prior reporting periods.  Thus, the new unit consumption data reported for these line items is equal to zero.   

Note: Utility data needs to be reported for each applicable utility type (i.e. Sewage and Water, Gas, etc.)

## Impact on Rolling BaseYear 1 - New Units Added

- No New Unit Consumption Data reported in Rolling base
- Use Line 07 – Actual Consumption for New Units

**Notes:**
In the first year, new units are funded (Year 1), there is no impact on Lines 02 03, or 04.  The additional new unit consumption is considered in Line 7 (Actual consumption for new units) for rolling base incentive purposes.

## Impact on Rolling BaseYears 2 to 5 After New Units Added

- Line 2 (Rolling base year 1) = Partial Year Data
- Report zero in rolling base year 1
- Use Line 7 – Actual Consumption for New Units
- Line 2 (Rolling base year 1) = Full Year Data
- Rolling base year 1 as reported
- Rolling base year 2 or 3 as reported or previous rolling base year
- Line 7 equals 0

**Notes:**
In years after new units become eligible (Years 2 to 5), the utility consumption incentive is included in HUD-52722 in two ways.  If the consumption data of new units for Line 2 (Rolling Base Year 1) consists of only a partial year data, then report zero for the rolling base line items – Line 02, 03 and 04.  The additional data will be included in Line 7 (Actual consumption for new units).  

However,  if the incremental consumption data of new units for Line 2 consists of a full year of data, then Line 7 (Actual consumption for new units) should equal zero, and Lines 02, 03 and 04 should include new unit consumption data.  If new unit data for Line 03 (Rolling base year 2) and Line 04 (Rolling base year 3) does not exist or only consists of a partial year of data, use the new unit amount from the earlier rolling base year.

## Deletion of Consumption Data Example

- Unit is added to the ACC and occupied by an eligible family on February 1, 2006
- Unit consumed 50 kwh of electricity consumption during reporting period
- Unit is expected to consume 120 kwh of electricity consumption annually

**Notes:**
The above bullet points show the necessary information to make an adjustment to HUD-52722 for a unit that was added to the ACC and occupied by an eligible family on February 1, 2006.

The unit consumed 50 kwh of electricity during the reporting period from February to June 2006.  This represented a partial year of data.  Based on the best estimates of utility experts, the unit should consume 120 kwh annually.  

## Adjustments to HUD-52722New Unit Consumption Data

| Line Item | FY 2007(7/1/05 to 6/30/06) | FY 2008 | FY 2009 | FY 2010 | FY 2011 |
| --- | --- | --- | --- | --- | --- |
| Line 1 - Actual Consumption | 50 | 115 | 130 | 140 | 150 |
| Line 2 - Rolling Base Year 1 | 0 | 0 | 115 | 130 | 140 |
| Line 3 - Rolling Base Year 2 | 0 | 0 | 115 | 115 | 130 |
| Line 4 - Rolling Base Year 3 | 0 | 0 | 115 | 115 | 115 |
| Line 7 - Actual Consumption for New Units | 50 | 115 | 0 | 0 | 0 |
| Line 14 - Annualization of Consumption for New Units | 70 | 0 | 0 | 0 | 0 |

**Full Year of Data**

**Partial Year of Data**

**Adjustment**

**Notes:**
The table above is an example of how to complete HUD-52722 if new units are added.  The example assumes that new units are added in FY 2007, 50 utility units of consumption given five unit months are included in Line 01 (Actual consumption).  Correspondingly, the 50 utility units are reported in Line 7 (Actual consumption for new units).  Finally, based on an average of ten utility units per unit month, it is estimated that 70 more utility units need to be reported in Line 14 (Annualization of consumption for new units).  

In FY 2008, 115 utility units are reported in Line 1 (Actual consumption).  Normally, the number of utility units reported in Line 02 (Rolling base year 1) would be equal to 50 utility units from the previous year.  However, because those 50 utility units only represent partial year data, the value reported in Line 2 (Rolling base year 1) should be zero.  Accordingly, the values for rolling base Lines 3 and 4 should also equal zero.  In order to consider the 115 new utility units in the utility consumption incentive, these units are reported in Line 07 (Actual consumption for new units).  Line 14 (Annualization of consumption for new units) is equal to zero, because Line 7 (Actual consumption for new units) consists of a full year of data.  

In FY 2009, 130 utility units are reported in Line 1 (Actual consumption) and 115 utility units are reported in Line 2 (Rolling base year 1) based on the amount in Line 1 (Actual consumption) from the previous year.  The 115 utility units consist of full year data.  As a result, new unit consumption data should be reported in Lines 2, 3 and 4.  However, because new unit utility data does not exist for Rolling Base Years 2 and 3, the value reported in Lines 3 and 4 will equal Line 2.  Line 7 (Actual consumption for new units) is now equal to zero.  

In FY 2010, data exists for Actual Consumption, Rolling Base Year 1 and Rolling Base Year 2.  Thus, Lines 1, 2, and 3 should be reported as is.   Line 4 should equal Line 3 (Rolling base year 3).

In FY 2011, new units can be treated as any other units.  Data exists for the current year of consumption and all rolling base years. 

## Exercise 6

- Refer to “New Units – Exercise 6” and forms HUD-52723 and HUD-52722