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S. HRG. 112–747 

STREAMLINING AND STRENGTHENING HUD’S 

RENTAL HOUSING ASSISTANCE PROGRAMS 

HEARING 

BEFORE THE

SUBCOMMITTEE ON 

HOUSING, TRANSPORTATION, AND COMMUNITY 

DEVELOPMENT 

AND THE

COMMITTEE ON 

BANKING, HOUSING, AND URBAN AFFAIRS 

UNITED STATES SENATE 

ONE HUNDRED TWELFTH CONGRESS 

SECOND SESSION 

ON 

EXAMINING HUD’S RENTAL HOUSING ASSISTANCE PROGRAMS 

AUGUST 1 and DECEMBER 11, 2012 

Printed for the use of the Committee on Banking, Housing, and Urban Affairs 

( 

Available at: http://www.fdsys.gov/ 

COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS 

TIM JOHNSON, South Dakota, Chairman 

JACK REED, Rhode Island 

CHARLES E. SCHUMER, New York 

ROBERT MENENDEZ, New Jersey 

DANIEL K. AKAKA, Hawaii 

SHERROD BROWN, Ohio 

JON TESTER, Montana 

HERB KOHL, Wisconsin 

MARK R. WARNER, Virginia 

JEFF MERKLEY, Oregon 

MICHAEL F. BENNET, Colorado 

KAY HAGAN, North Carolina 

RICHARD C. SHELBY, Alabama 

MIKE CRAPO, Idaho 

BOB CORKER, Tennessee 

JIM DEMINT, South Carolina 

DAVID VITTER, Louisiana 

MIKE JOHANNS, Nebraska 

PATRICK J. TOOMEY, Pennsylvania 

MARK KIRK, Illinois 

JERRY MORAN, Kansas 

ROGER F. WICKER, Mississippi 

DWIGHT FETTIG, Staff Director 

WILLIAM D. DUHNKE, Republican Staff Director 

CHARLES YI, Chief Counsel 

BETH COOPER, Professional Staff Member 

ERIN BARRY FUHRER, Professional Staff Member 

BRETT HEWITT, Legislative Assistant 

DAWN RATLIFF, Chief Clerk 

RIKER VERMILYE, Hearing Clerk 

SHELVIN SIMMONS, IT Director 

JIM CROWELL, Editor 

SUBCOMMITTEE ON HOUSING, TRANSPORTATION, AND COMMUNITY DEVELOPMENT

ROBERT MENENDEZ, New Jersey, Chairman 

JIM DEMINT, South Carolina, Ranking Republican Member 

JACK REED, Rhode Island 

CHARLES E. SCHUMER, New York 

DANIEL K. AKAKA, Hawaii 

SHERROD BROWN, Ohio 

JON TESTER, Montana 

HERB KOHL, Wisconsin 

JEFF MERKLEY, Oregon 

MICHAEL F. BENNET, Colorado 

MIKE CRAPO, Idaho 

BOB CORKER, Tennessee 

PATRICK J. TOOMEY, Pennsylvania 

MARK KIRK, Illinois 

JERRY MORAN, Kansas 

ROGER F. WICKER, Mississippi 

MICHAEL PASSANTE, Subcommittee Staff Director 

JEFF R. MURRAY, Republican Subcommittee Staff Director 

(II)

(III) 

C O N T E N T S 

WEDNESDAY, AUGUST 1, 2012 

Page 

Opening statement of Chairman Menendez .......................................................... 1 

Prepared Statement ......................................................................................... 21 

Opening statements, comments, or prepared statement of: 

Senator Reed ..................................................................................................... 2 

WITNESSES 

Keith Kinard, Executive Director, Newark Housing Authority, on behalf of 

the Council of Large Public Housing Authorities .............................................. 4 

Prepared statement .......................................................................................... 22 

Response to written questions of: 

Senator Schumer ....................................................................................... 87 

Dianne Hovdestad, Deputy Director, Sioux Falls Housing and Redevelopment 

Commission, on behalf of the National Association of Housing and Redevelopment Officials ................................................................................................... 6 

Prepared statement .......................................................................................... 52 

Response to written questions of: 

Senator Schumer ....................................................................................... 89 

Howard Husock, Vice President for Policy Research, Manhattan Institute ....... 7 

Prepared statement .......................................................................................... 60 

Will Fischer, Senior Policy Analyst, Center on Budget and Policy Priorities .... 9 

Prepared statement .......................................................................................... 62 

Response to written questions of: 

Senator Schumer ....................................................................................... 101 

Linda Couch, Senior Vice President for Policy and Research, National Low 

Income Housing Coalition ................................................................................... 11 

Prepared statement .......................................................................................... 76 

Response to written questions of: 

Senator Schumer ....................................................................................... 105 

ADDITIONAL MATERIAL SUPPLIED FOR THE RECORD

Letters submitted by Dianne Hovdestad ............................................................... 107 

NAHRO Voucher Administrative Fee Survey Results ......................................... 116 

Statement submitted by Deborah De Santis, President and Chief Executive 

Officer, Corporation for Supportive Housing ..................................................... 120 

Statement submitted by Kristina Cook, CAE, on behalf of the National Affordable Housing Management Association ....................................................... 127 

Memorandum: Proposed Regulatory and Administrative Reforms and Statutory Language ....................................................................................................... 132 

Letter from the Preservation Working Group ....................................................... 158 

Letter to the Senate Banking Committee regarding Section 8 voucher reform . 160 

TUESDAY, DECEMBER 11, 2012 

Opening statement of Chairman Johnson ............................................................. 163 

WITNESS 

Sandra B. Henriquez, Assistant Secretary for Public and Indian Housing, 

Department of Housing and Urban Development ............................................. 164 

Prepared statement .......................................................................................... 174 

(1) 

STREAMLINING AND STRENGTHENING HUD’S 

RENTAL HOUSING ASSISTANCE PROGRAMS—PART I 

WEDNESDAY, AUGUST 1, 2012 

U.S. SENATE, 

SUBCOMMITTEE ON HOUSING, TRANSPORTATION, AND

COMMUNITY DEVELOPMENT, 

COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS, 

Washington, DC. 

The Subcommittee met at 10:02 a.m., in room SD–538, Dirksen 

Senate Office Building, Hon. Robert Menendez, Chairman of the 

Subcommittee, presiding. 

OPENING STATEMENT OF CHAIRMAN ROBERT MENENDEZ 

Chairman MENENDEZ. Good morning. This hearing of the Senate 

Banking Committee’s Subcommittee on Housing, Transportation, 

and Community Development will examine opportunities to improve the Department of Housing and Urban Development’s rental 

housing assistance programs, particularly the Section 8 and public 

housing programs. 

Section 8 and public housing programs put a roof over the heads 

of a combined 3.5 million American families, from formerly homeless veterans of our Nation’s armed forces to hard-working single 

parents with children to elderly and disabled families. Over the 

past several years, these programs have performed to high standards while operating under dire funding constraints, but we can 

clearly see the strain. 

In March, HUD Secretary Shaun Donovan testified that 18 housing authorities had given up their voucher programs since January 

and two housing authorities had turned down the HUD–VASH 

vouchers to assist homeless veterans because they could not afford 

to administer these programs. 

Meanwhile, for the better part of a decade now, Congress has 

been debating proposals to enact a package of changes to these 

rental assistance programs, changes which have the potential to 

improve outcomes for low-income families while saving the Federal 

Government money and easing the administrative and regulatory 

burden on housing authorities. 

The names of the bills have changed from the Section 8 Voucher 

Reform Act to the Section 8 Savings Act and now the Affordable 

Housing and Self-Sufficiency Improvement Act, but many of the 

provisions have remained remarkably consistent and enjoy substantial bipartisan support. 

2 

Many of these provisions just make good sense. For example, it 

makes sense to recheck the incomes of participant families on fixed 

incomes less frequently since the incomes of these families are 

more stable. It makes sense to make families with high net assets 

ineligible for housing assistance through these programs. It makes 

sense to streamline housing inspections and to relieve housing authorities of the burden of inspecting housing units that have already passed inspection under another State or Federal program. 

And it makes sense to allow housing authorities to pay higher rental subsidies for families with disabilities if the higher rent is needed to enable the family to live in an accessible home. I believe my 

colleagues and I can agree on many of these commonsense provisions, and I look forward to highlighting these areas of consensus. 

Changes to HUD’s rental assistance programs have also been 

linked to proposals related to other HUD programs, including the 

Family Self-Sufficient Program, the Rental Assistance Demonstration, Moving to Work Demonstration, among others. Our discussion 

today will shed greater light on these important proposals and, in 

particular, contribute to the dialog around a balanced expansion of 

the Moving to Work Program that builds on the success of the current demonstration while implementing a rigorous evaluation system and protecting assisted families from policies imposing severe 

burdens. 

HUD’s rental assistance programs enable millions of low-income 

Americans to live in safe and affordable homes. It is critical that 

we make these programs more efficient and place them on a stable 

footing for the future so that they can remain available to the most 

vulnerable members of our society. 

I look forward to hearing the witnesses’ testimony on changes 

that would move us toward this goal by improving outcomes for 

residents, reducing program costs, and streamlining requirements 

for housing authorities. 

Senator Reed, would you like to make an opening statement? 

STATEMENT OF SENATOR JACK REED 

Senator REED. Well, thank you very much, Mr. Chairman. I want 

to welcome the witnesses and particularly thank you for holding 

this very important hearing. 

As today’s hearing will explore, we are looking for ways to 

streamline and strengthen HUD’s rental housing assistance programs, and I would like to focus my brief comments on a key approach to accomplish this goal, and that is the enhancement of the 

Family Self-Sufficiency Program. 

Family Self-Sufficiency is an employment and saving incentive 

program for families that have Section 8 vouchers or live in public 

housing. This program provides at least two key tools for its participants: first, it provides access to the resources and training that 

helps participants pursue employment opportunities and other 

goals; and, second, it encourages FSS families to save money by establishing an escrow account for them. And upon graduation from 

the FSS program, the family can use these savings to pay for jobrelated expenses such as the purchase and maintenance of a car or 

for additional workforce training. 

3 

I will soon be introducing legislation to enhance the FSS Program as it exists today which will broaden the supportive services 

that can be provided to participants, including GED prep and financial literacy training, and extend the FSS Program to participants who live in privately owned properties with project-based assistance. And I would urge all my colleagues to look very closely 

at the bill, and hopefully they will be supportive. 

Finally, I will continue to work to fund the National Housing 

Trust Fund, and I reiterate my willingness to work with all my colleagues to realize this goal. 

One point I think I want to just emphasize is that there is something more that we have to do than simply provide shelter. You 

have to provide people the ability to move up and move forward, 

and the FSS Program does it. So without supportive services, I 

think we end up in the long run spending a lot more money and 

not giving people the chance to use their talents to move up and 

move out and move on. And that should be our goal just as much 

as providing basic shelter. 

Thank you, Mr. Chairman. 

Chairman MENENDEZ. Thank you, Senator. 

Let us welcome all of our witnesses. As I introduce you, let me 

just say that your full testimony will be included in the record. We 

ask you to summarize your testimony in around 5 minutes or so, 

and then that will be followed by a question-and-answer period. 

Let me introduce our panel. Keith Kinard is the executive director of the Newark Housing Authority in New Jersey since June 

2006. That is the largest public housing authority in the State of 

New Jersey, managing over 11,000 public housing units and housing choice vouchers. It also serves as the redevelopment authority 

for the city, working in support of the revitalization of the city of 

Newark. Prior to that, Mr. Kinard was the executive director of the 

Pittsburgh Housing Authority, which participates in the Moving to 

Work Demonstration, so we look forward to hearing his insights on 

that. He is testifying today on behalf of the Council of Large Public 

Housing Authorities, of which he is a board member. Welcome, 

Keith. We look forward to your testimony. 

Dianne Hovdestad is the deputy director of the Sioux Falls Housing and Redevelopment Commission in Sioux Falls, South Dakota. 

She is responsible for the day-to-day administration of programs 

that provide affordable housing to approximately 2,000 households, 

including 1,800 housing choice vouchers. She has over 35 years of 

experience—they must have taken you from the crib to do this 

work—working with HUD rental assistance programs and has 

served in various leadership positions with the National Association of Housing and Redevelopment Officials, including the vice 

president of the housing committee, and she testifies on their behalf today. 

Howard Husock is vice president for policy research at the Manhattan Institute where he is also director of its Social Entrepreneurship Initiative, a contributing editor to City Journal, has written widely on housing and urban policy, has served as director of 

case studies in public policy and management at Harvard University’s Kennedy School of Government, where he is also a fellow at 

4 

the Hauser Center for Nonprofit Organizations. We welcome you as 

well. 

Will Fischer is a senior policy analyst at the Center on Budget 

and Policy Priorities. His work focuses on Federal low-income housing programs, including the Section 8 Voucher Program, public 

housing programs, the Low-Income Housing Tax Credit Program 

has been cited in numerous media publications, and we welcome 

him. 

Linda Couch is the senior vice president for policy and research 

at the National Low Income Housing Coalition. In this role, Linda 

focuses on issues including public and assisted housing, appropriations, capitalization of the National Housing Trust Fund. She has 

previously worked at Leading Edge on affordable housing for lowincome seniors. She also has a background in State Government affairs. 

So we have a very talented set of panelists. With that, we are 

going to start with you, Mr. Kinard, and, again, about 5 minutes, 

and then we will move on to the rest of the panelists and have a 

good question-and-answer session. 

STATEMENT OF KEITH KINARD, EXECUTIVE DIRECTOR, NEWARK HOUSING AUTHORITY, ON BEHALF OF THE COUNCIL OF 

LARGE PUBLIC HOUSING AUTHORITIES 

Mr. KINARD. Good morning, Chairman Menendez, Senator Reed, 

and other Members of the Subcommittee. My name is Keith 

Kinard. I am the executive director of the Newark Housing Authority and a board member of the Council of Large Public Housing Authorities. CLPHA’s 70 members serve over 1 million households, 

manage almost half the Nation’s public housing stock, and administer nearly one-quarter of the Section 8 program. 

With the proposed AHSSIA legislation, Congress has recognized 

the need for revision of the Housing Choice Voucher Program to 

allow agencies to operate more efficiently. There are several aspects of AHSSIA that would undoubtedly improve the Housing 

Choice Voucher Program. The first is allowing families with fixed 

incomes to recertify at least 3 years in lieu of the annual recertification requirement. Current HUD regulations require all assisted 

families to recertify annually. This creates a significant incessant 

administrative task. Of those 4,500 families on the program in 

Newark, nearly 40 percent, or 1,800, rely on fixed income to support their families. The provisions of AHSSIA that allow the reexamination to take place every 3 years would greatly reduce the 

costs associated with the current process. 

The second improvement is curbing the volume of unplanned interim reexaminations performed at the participant’s request. Our 

agency received approximately 180 requests for interim reexaminations last month alone, or 2,500 annually. New provisions in 

AHSSIA setting a 10-percent decline threshold and giving housing 

authorities discretion on whether to complete an interim recertification if the change in income occurs within 3 months preceding 

the annual recertification are a welcome option to housing authorities’ avoiding duplicative work. 

An additional positive recommendation is the allowance of biennial housing quality standard inspections. The Newark Housing 

5 

Authority must conduct a minimum of 4,500 annual HQS inspections per year. That equates to 87 per week and spending roughly 

$160,000 annually. It is the Newark Housing Authority’s position 

that through this reform effort, landlords should bear the cost for 

required second and third inspections that occur due to the failing 

condition of units. 

The Rental Assistance Demonstration Program is a step in the 

right direction toward converting public housing rental portfolio. 

Public housing nationwide carries a $26 billion capital backlog due 

to funding issues and an aging inventory. Newark Housing Authority alone has $500 million in capital needs and receives just over 

$16 million annually. This is a recipe for failure. RAD begins to 

offer a path to allow conversion and preservation through private 

investment in our public housing stock. The current House version 

of AHSSIA is strongly supported by CLPHA because it not clears 

up many aspects of the process, but it also authorizes appropriations of $30 million annually over the next 5 years in order to supplement costs, evaluate the program, and provide much needed 

technical assistance to authorities and residents. 

We do, however, believe that HUD should use to the maximum 

extent possible their waiver authority to address current limitations on contract rent setting, the cap on the number of PBV units, 

and also the 12-month choice mobility constraint. 

Finally, we support the permanent expansion of the Moving to 

Work Program for any interested housing authorities. Currently 35 

MTW agencies are managing a program that falls outside the 

bounds of the traditional models and are raising overall standards 

of housing services. Innovative programs dealing with rent simplification, preservation of expiring use properties, and funding of 

housing for the chronically homeless are just a few initiatives that 

were born out of the MTW Program. Having run both an MTW 

agency and a nontraditional non-MTW housing authority, I can attest to the major benefits that residents, the community, and the 

housing authorities alike realize in an MTW environment. In Newark, a non-MTW agency, we are consistently drawn to focus on 

HUD test protocols such as PHAS, SEMAP, PIC, and VMS submissions. This diverts attention away from families we serve and the 

outcomes we strive to achieve. 

In my previous role as the executive director of the Pittsburgh 

Housing Authority, we utilized a broad range of MTW flexibility to 

address the more critical needs in our community. We began our 

days thinking about creating affordable housing within intensive 

supports, eliminating high-cost/low-benefit activities required by 

regulation, and focusing cash, regardless of its origin, on creating 

new affordable housing and preserving the existing stock. 

In sum, CLPHA strongly supports the expansion of MTW and 

this assisted housing reform effort, and we thank you all for the 

opportunity to provide testimony on these critical issues. 

Chairman MENENDEZ. Thank you very much. 

Ms. Hovdestad. 

6 

STATEMENT OF DIANNE HOVDESTAD, DEPUTY DIRECTOR, 

SIOUX FALLS HOUSING AND REDEVELOPMENT COMMISSION, ON BEHALF OF THE NATIONAL ASSOCIATION OF 

HOUSING AND REDEVELOPMENT OFFICIALS 

Ms. HOVDESTAD. Good morning, Chairman Menendez, Senator 

Reed, Senator Crapo. My name is Dianne Hovdestad, and I serve 

as the deputy director of the Sioux Falls Housing and Redevelopment Commission in South Dakota. I am also representing the 

22,000 individual members and 3,200 agency members of the National Association of Housing and Redevelopment Officials, the oldest and largest group representing housing and community development professionals. I am here representing many, many housing 

authorities across the Nation. 

The voucher program is a difficult program to administer and 

difficult for households and landlords to participate in as the regulations are very complex. My written testimony has many recommendations of what I hope you will consider enacting, but there 

are three things I implore you to consider based on my 35 years 

of experience in administering rental assistance programs: 

One, adequate funding for administration of the program, on the 

budget appropriations side, that Congress provides adequate funding for the administration of the voucher program. In many ways, 

Sioux Falls Housing is indicative of a great number of housing authorities serving rural, geographically large areas. I mention this 

because the impact of the current situation with the administrative 

fees affects both large urban housing authorities as well as smaller 

rural housing authorities, but in substantially different ways. 

Given this need, the time for relief is now. I will use Sioux Falls 

Housing administrative fees to demonstrate how difficult it has become. 

In fiscal year 2003, Sioux Falls Housing earned approximately 

$970,000 to administer $7.3 million in voucher rental assistance for 

1,500 households. In calendar year 2012, Sioux Falls Housing anticipates that it will receive approximately $950,000 to administer 

$10 million in rental assistance for approximately 1,800 households. Sioux Falls Housing is receiving less money to administer $3 

million more in rental assistance to an additional 316 households. 

I am pleased that Chairman Johnson recognized that housing authorities could not perform all the required program tasks based on 

the pro-ration in 2012. In order to assist housing authorities, Senator Johnson introduced an amendment to address this issue. I 

hope you will address the administrative fee in any legislation that 

you develop. 

Two, rent simplification. The determination of a household’s income which is used to calculate the amount of rental assistance 

and the household’s share of rent is an extremely complicated process. Every source and amount of a household’s income must be 

verified by a third party and reported to HUD. This includes 

amounts that are specifically excluded by statute and/or regulation. 

Each household participating in the voucher program must provide 

information annually to determine if an adjustment should be 

made in the amount of their rental assistance and tenant share of 

the rent. Each interview takes approximately 30 to 45 minutes to 

complete. I am asking that the complexities of the rent calculation 

7 

requirements be alleviated through quick rulemaking changes so 

long as statutory requirements are met. A rapid response to this 

request would mean immediate relief to staff time currently dedicated to meeting the current complex requirements. Changes would 

alleviate the administrative costs associated with the current calculations regime and result in a twofold effect of reducing administrative costs currently associated with the current rent calculation 

regime while also providing immediate relief to address my request. 

Three, regulatory relief. Housing authorities across the country, 

whether small rural agencies like the one I serve or the larger 

urban communities, desperately need responsible regulatory reform. I am respectfully requesting that you bring your significant 

influence to bear at this time to stress to the Department the urgent need for quick action. For nearly 10 years, the National Association of Housing and Redevelopment Officials has urged the Department to take quick action. With your permission, I would like 

to submit the Mountain Plains NAHRO’s request for regulatory relief and the Department’s response for the record. 

Chairman MENENDEZ. Without objection. 

Ms. HOVDESTAD. Positive action on requested regulatory relief by 

the Department would provide not only the regulatory relief I mentioned but, more importantly, increase staff time to address the important matters of providing excellent customer service to our community, greater transparency to our landlords participating in the 

voucher program, and place low-income families in safe, quality 

housing. 

Thank you. 

Chairman MENENDEZ. Thank you. 

Ms. Husock. 

STATEMENT OF HOWARD HUSOCK, VICE PRESIDENT FOR 

POLICY RESEARCH, MANHATTAN INSTITUTE 

Mr. HUSOCK. Thank you, Mr. Chairman, and thanks to this Committee for devoting its time and attention to the important issues 

of low-income housing. 

The legislation recently considered by the House focused both on 

how best to finance and maintain affordable housing and how to 

structure tenant-based low-income housing programs so as to encourage self-sufficiency and upward mobility. I will focus mainly on 

the Housing Choice Voucher Program and, particularly, the Moving 

to Work Program, which, like Mr. Kinard, I will strongly support. 

Over the past two decades, housing vouchers have emerged as a 

major program for many of our lowest-income households, roughly 

doubling in size. In fiscal year 1998, the Congress appropriated $9 

billion for local public housing authorities to distribute vouchers. 

More recently, HUD has allocated $17 billion for that same purpose. Spending on vouchers has even surpassed the cash benefits 

of Temporary Assistance for Needy Families. 

One can well understand why the challenge for the lowest-income families earning 30 percent or less of median to find housing 

is substantial. It is important, however, to understand the housing 

choice voucher not just as a housing program but, in addition, as 

a key aspect of U.S. social policy, that is, our policy aimed at aiding 

8 

the long-term upward mobility of the most disadvantaged households. That traditional goal of social policy—what President Johnson called a ‘‘hand up’’—is relevant to this program in which many 

of the most vulnerable households are enrolled. 

Like traditional public housing, nonelderly voucher recipients 

with children are largely single-parent families, 94 percent headed 

by single women; and they are of extremely low income, 47 percent 

at 20 percent or less of national median. So the importance of 

structuring the program to provide incentives such that households 

move toward economic self-sufficiency is crucial. But this also has 

a practical dimension. The long waiting list and the likelihood that 

appropriations will not be significantly increased means it behooves 

us to find ways to help the participants move up and out if only 

to serve others in need. But HUD data shows that currently 50 

percent of voucher tenants and 48 percent of public housing tenants have been in the program for 5 years or longer. 

It is in this context that it is crucial to set goals for the program 

that go beyond administrative efficiency, as important as that is, 

and that public housing authorities which administer the program 

seek to improve such metrics as employment, household income, 

and the graduation, if you will, from the program. To find the best 

ways to manage and structure it so as to achieve these goals, it 

makes sense to give the Nation’s network of 3,200 public housing 

authorities flexibility based on the model of efforts authorized 

under the modestly scaled, too modestly, Moving to Work initiative, 

which should be made permanent and expanded to include as 

many authorities as possible. 

We are already seeing very significant social improvement 

through Moving to Work to date. Notably, the Atlanta Housing Authority has used its MTW waiver to link a work requirement with 

extensive counseling to the voucher, and they have increased work 

participation among voucher holders—among its housing population, rather, from 14 percent in 1994 to 71 percent today. Other 

authorities—including Cambridge, Massachusetts; Charlotte, North 

Carolina; Portland, Oregon; Ravenna, Ohio; the State of Delaware—are using MTW in ways to change their rent structure so as 

to stop discouraging work and to encourage savings. An expansion 

of Moving to Work would allow other authorities to try similar experiments, even to consider, as Philadelphia did, an outright time 

limit. 

Flexibility for local housing authorities must be guided by clear 

goals shaped by the Congress and overseen by HUD, but there is 

just no reason to limit the flexibility that comes with Moving to 

Work, an initiative begun by the Clinton administration, to just 35 

of the Nation’s 3,200 housing authorities. 

Finally, I would like to address briefly the proposal also discussed in the House bill’s language to convert public housing capital and operating subsidies into project-specific vouchers, both as 

a means to preserve affordable housing developments in their current use and to facilitate increased investment of private capital to 

reduce an estimated $30 billion in maintenance backlog. The rationale for doing this in a time of serious maintenance needs and 

budget shortfalls is obvious, and the approach may provide a useful 

9 

additional tool for public housing officials facing serious deferred 

maintenance. 

I would urge, however, that Members of the Committee be cautious in a too broad embrace of this plan which could be fiscally 

consequential. Anytime public incentives divert private capital, we 

cannot be sure what opportunities we are forgoing, and the same 

is true for preserving specific housing developments when there 

may be a higher and better use for their sites in ways which could 

benefit those of all income. 

Innovative maintenance financing may be worth trying in a limited number of circumstances but should not be seen, in my view, 

as a way to preserve unit by unit all public and subsidized housing. 

Better for the Congress through HUD to encourage additional approaches which could include, for instance, the sale of high-value 

parcels currently owned by local housing authorities so as to create 

locally based maintenance endowments for remaining units. 

Let us be guided both in how much public housing we preserve 

and how we set the rules for housing choice vouchers not by a narrow goal of preservation or program expansion, but by a broad determination to help improve the economies of our cities in ways 

that uplift the poorest households. 

Thank you very much. 

Chairman MENENDEZ. Thank you. 

Mr. Fischer. 

STATEMENT OF WILL FISCHER, SENIOR POLICY ANALYST, 

CENTER ON BUDGET AND POLICY PRIORITIES 

Mr. FISCHER. Thank you, Chairman Menendez, Senator Reed, 

and Members of the Subcommittee. It is a privilege to testify before 

you today, and I want to thank you also for holding this hearing 

on the important topic of strengthening and streamlining Federal 

rental assistance. 

The Nation’s rental assistance programs assist more than 4 million low-income families, most of them elderly people, people with 

disabilities, and working-poor families with children. Research has 

shown these programs to be highly effective in addressing problems 

like homelessness and housing instability, but it has been a long 

time—14 years—since Congress has enacted authorizing legislation 

covering the voucher and public housing programs, and there are 

opportunities to improve the programs based on lessons learned 

and changed circumstances. 

Both AHSSIA, the bill that the House considered this year, and 

the Section 8 Voucher Reform Act that Congress has considered in 

previous years contain a set of largely similar core reforms that 

would strengthen and update these programs through reducing administrative burdens for agencies and owners, allocating voucher 

funds more efficiently, and strengthening support for work. 

Even more pressing, these bills contain large Federal savings. 

According to CBO, the December 2010 version of SEVRA, which is 

the most recent, would reduce the amount of funding needed to 

maintain the current level of rental assistance by more than $700 

million over 5 years. According to the Financial Services Committee, the most recent version of AHSSIA, which contains some 

additional cost savings measures, increases that to $1.5 billion. 

10 

Those numbers do not include savings from administrative streamlining which would reduce costs by an additional several hundred 

million dollars. 

My testimony contains details on the core reforms in these bills. 

Just as one example, I think the provisions streamlining determination of tenant rents and incomes are one of the key reforms 

that would really reduce administrative burdens as well as generating other cost savings. The change to doing recertifications for 

people in fixed incomes every 3 years, as has been mentioned, is 

a good example of that. That would reduce burdens on mostly elderly people and people with disabilities who would be affected and 

also generate large administrative savings for agencies. It is just 

one of a large number of similar commonsense, good Government 

reforms that are in these bills. These are largely proposals that 

HUD supports but cannot move forward with without congressional 

authorization. They have been vetted for a number of years in Congress and have had strong bipartisan support, and they are supported by a broad range of housing groups, as evidenced by the letter from 810 organizations around the country that was sent to the 

Banking Committee urging prompt action. 

I would urge the Committee to be cautious with more controversial provisions. For example, a sharp expansion of the Moving to 

Work Program raises a number of risks, such as large shifts of 

funds from the voucher program to other purposes that would result in many fewer families receiving assistance. And any Moving 

to Work expansion that goes beyond the compromise provision that 

is in the most recent House bill would also undermine the broad 

support that the bill has received so far. 

I want to close by just emphasizing how important it is that the 

country’s rental assistance programs work as efficiently and as effectively as possible so that they can assist as many families as 

they can. In concrete terms, the savings in these bills would mean 

that housing agencies can serve more needy families or, if necessary, avoid painful cuts in assistance. These are critically important changes, especially now when budgets are expected to be tight 

for years to come, but the need for rental assistance remains very 

high with fewer than one in four families eligible for assistance getting help. 

The voucher reform bills, the rental assistance reform bills would 

take a big step toward achieving those goals of improving these 

programs, and I would urge the Congress to enact them as soon as 

possible so that the savings and other benefits from the programs 

can begin to be realized as soon as possible. 

Thanks again for the privilege of testifying before you, and I will 

be happy to take any questions that you have. 

Chairman MENENDEZ. You are so efficient. You had another 

minute. 

[Laughter.] 

Chairman MENENDEZ. Ms. Couch. 

11 

STATEMENT OF LINDA COUCH, SENIOR VICE PRESIDENT FOR 

POLICY AND RESEARCH, NATIONAL LOW INCOME HOUSING 

COALITION 

Ms. COUCH. On behalf of the National Low Income Housing Coalition, I would like to thank Chairman Menendez for holding this 

important hearing today at a time when the need for rental assurance is growing across the United States. 

The shortage of affordable and available units for extremely low 

income households in 2010 was 6.8 million units, 400,000 more 

than it was in 2009. For extremely low income households, there 

is a shortage of more than 189,000 affordable and available units 

in New Jersey alone. 

Ideally housing reform legislation would result in both more affordable housing and more efficient use of Government resources. 

Recent versions of housing reform legislation would result in 5-year 

savings ranging from around $700 million to more than $1 billion. 

These are tremendous savings, the vast majority of which come 

from uncontroversial policy changes. 

In any reform bill, we urge the Subcommittee to balance new 

program flexibilities with the need for program accountability. In 

the long run, we fear that if Congress’ understanding of the program’s use and impact fade due to fewer reporting requirements, 

the result would be decreased resources. The reforms that we support bring efficiencies while continuing to hold all parties accountable for the use of Federal resources. 

We support several changes that would encourage increased 

earned income and simplify rent setting while maintaining Brooke, 

the program’s underlying tenet that each household pays a rent 

that is affordable, even as its income fluctuates. 

The Nation would also benefit from enactment of improvements 

to the project basing of vouchers, which would allow otherwise 

unaffordable units to meet the Nation’s most significant affordable 

housing needs. 

The need for clear direction to HUD on the allocation of voucher 

renewal funding was a primary reason for the development of reform legislation several years ago. We support language directing 

HUD to base renewals on actual costs and leasing data as well as 

policies that would allow agencies to over-lease vouchers and reserve offset and reallocation policies. 

We would like any Senate housing reform bill to include provisions to improve the portability of vouchers from one housing agency’s jurisdiction to another, to require HUD to establish certain 

standards and procedures for assessing the performance of agencies’ voucher programs, and to guard voucher households from paying excessive rent burdens. Each of these provisions improve the 

voucher program for tenants, and each has thus far been left out 

of the House versions of the bill this session. 

On another note, the Low Income Housing Coalition was shocked 

and disappointed that the Administration requested increased minimum rents in its fiscal year 2013 budget request. We referred to 

HUD’s proposal as one that ‘‘picks the pockets of the poorest of the 

poor.’’ It follows then that we do not believe increasing minimum 

rents is needed to create a robust housing reform bill. The House’s 

latest proposal increases minimum rents for households with inVerDate Nov 24 2008 09:17 Apr 26, 2013 Jkt 048080 PO 00000 Frm 00015 Fmt 6633 Sfmt 6633 L:\HEARINGS 2012\08-01 & 12-11 HUD S RENTAL HOUSING ASSISTANCE PROGRAMS, 
12 

comes of less than $2,800 a year. While it may be hard to imagine 

that there are households with incomes so low, the reality is that 

these households exist, and the programs keeping them off the 

street, out of the back seats of cars at night, and out of shelters 

are HUD’s voucher, public housing, and project-based Section 8 

programs. 

We also support other major reforms to the voucher program 

which we know are outside of the scope of any bill this year. Three 

policies that would significantly increase households’ choice and 

ability to use their vouchers are the regionalization of voucher assistance and administration, the enactment of Federal source of income laws, and instituting nationwide small-area fair market 

rents, an effort for which HUD is currently doing a demonstration. 

Of course, a real breakthrough would be to make assistance by 

the Housing Choice Voucher Program an entitlement to those 

households eligible for it, at least for certain populations. Today the 

only housing entitlement programs are for homeowners, the vast 

majority of those resources going to assist high-income households. 

While the coalition has agreed to a carefully crafted version of 

Moving to Work expansion, referred to by others here as the 

‘‘stakeholder agreement,’’ and I believe attached to CLPHA’s testimony, history shows that Moving to Work expansion has stalled 

housing legislation for years. We support moving forward with 

voucher reform legislation without an MTW title. Moving to Work 

legislation could be considered separately while the significant savings and efficiencies of a broader housing reform bill could be taken 

advantage of now. 

We also encourage Members of this Subcommittee to support 

capitalization of a National Housing Trust Fund, which Congress 

authorized in 2008 thanks to the leadership of Senator Reed. The 

National Housing Trust Fund, coupled with the stabilization of 

HUD’s rental assistant programs by housing reform legislation, 

could end homelessness in the United States. 

Thank you for your work to improve HUD’s programs. 

Chairman MENENDEZ. Thank you. Thank you all. 

There is a lot of ground to cover here, so let me start with you, 

Mr. Kinard and Ms. Hovdestad. Both of you are on the ground. You 

are working every day to implement these programs on behalf of 

low-income families. We have been talking about this for some 

time. I think there is a tendency to forget how incredibly pressing 

the need for action really is. I have heard from affordable housing 

advocates and housing professionals telling me that these reforms 

really cannot wait and are urgently needed now. 

Can you discuss the impact over time if Congress fails to act soon 

to implement some of the specific reform proposals we have talked 

about? What are the consequences on the ground? 

Mr. KINARD. I certainly can do some of that. The consequences 

really are devastating. There are financial consequences associated 

with cumbersome, burdensome processes that simply we cannot afford and each year are escalating. There is the potential for loss of 

units. We have many units in Newark alone right now that are 

boarded up, that we simply do not have the funding to put back 

online. And a lot of our funding is being used today to ultimately 

fill out score sheets and fill out reports and send information in. 

13 

And it is really sad riding to work every day past units that have 

the windows boarded up and the doors boarded up, knowing that 

we have waiting lists that have thousands and thousands of families on them for many, many years, and realizing that I have got 

to divert that funding to ultimately respond to needs that have 

been on regulatory books for many, many years, and unfortunately 

really do not get to the heart of the mission that we are in business 

to do. 

So essentially for the availability of future housing, for, I think, 

the future existence of our program, and especially in light of the 

outlook of budgets moving forward in forward years, I think the 

impact is devastating if we do not move soon. 

Ms. HOVDESTAD. I would like to echo what was just said and that 

we do spend a lot of time working on reports that we have not had 

to do in the past. HUD is putting a lot of emphasis on lease-up, 

and so every month we respond to questions from HUD about why 

we are not leasing up to our baseline units. And part of our problem of underutilization of our vouchers is that we are unable to 

hire staff that has left the agency’s employ for other jobs, and so 

the rest of the workload is distributed to the other staff, and they 

cannot take on any more than they currently have. It is taking 

longer to get the inspections done because of the lack of staff. And 

then the interim changes that we are required to do, they are taking a lot of time also. 

Another big impact is on the Family Self-Sufficiency Program 

that we have, and I would like to thank Senator Reed for his work 

on the FSS Program. We have a very successful Family Self-Sufficiency Program, and we were able to use some of our administrative fees to help meet some of the unmet needs like personal counseling. We have a lot of participants who have a lot of personal 

issues that are barriers for them becoming self-sufficient. We have 

used it to put on workshops on financial wellness and what it takes 

to buy a house and things like that. 

On the regulatory side, we just spend a lot of time kind of doing 

things that seem kind of redundant and unnecessary, like the reporting of excluded income. 

Chairman MENENDEZ. Since you are both representing a different universe of housing authorities here, what is the reality of 

housing authorities’ refusing to run their voucher programs, turning down VASH vouchers to assist homeless veterans, loss of hard 

units as a result of the lack of reforms? With your colleagues, do 

you experience that? 

Mr. KINARD. Well, I feel that. We have not done that. We have 

not been forced to do that. But we have had to make similar decisions, and I will give you a concrete example that we face on a 

monthly basis. 

Due to reduced admin fees and due to our strain in terms of resources, we are making decisions in terms of how many staff we 

have associated with interim reexamination processes and annual 

reexamination processes versus our ability to actually issue vouchers and get families on the program. It is a budgetary issue. It is 

a commonsense issue. If you only have ten staff and that is all you 

can afford, but you must get these forms in, somewhere in there 

you have got to make a decision between the two. And I believe 

14 

those housing authorities have made probably the most difficult 

choice in many of those directors’ and staffs’ career that they do not 

want to provide insufficient service or they do not want to jump 

into something that ultimately will provide less than decent, safe, 

and sanitary housing. Instead, they will turn those vouchers in, 

and hopefully someone else can utilize those correctly because they 

simply do not have the funding to run the program. 

Chairman MENENDEZ. All right. I have several other questions, 

but I want to turn to Senator Reed first. 

Senator REED. Well, thank you, Mr. Chairman, and I want to 

thank the witnesses for excellent testimony and giving great perspectives on some very critical issues. I think Mr. Husock pointed 

out that it is not just about keeping people in housing; it is giving 

them a chance to move up, move forward, move ahead. And I think 

that is a theme that we want to support. 

That takes me back to the point I raised in my opening statement about the Family Self-Sufficiency Act. Thank you, Dianne, for 

using it so well and effectively. But I wondered, Mr. Fischer, with 

your colleagues at the Center on Budget and Policy Priorities, have 

you looked at this issue and can you give some comments about 

how valuable the program is and what we can do to continue it? 

In terms of changes, HUD is making similar proposals as I am. 

Mr. FISCHER. Sure. I think this is an important issue to look at, 

ways to help people who receive rental assistance move toward selfsufficiency. As context, there are a lot of people on rental assistance for whom this is not an issue. Half of the caseload is elderly 

people or people with disabilities. Another 30 percent is working 

families. But there is a segment of the population that could use 

support to help move toward self-sufficiency and increase their 

earnings, and I think the Family Self-Sufficiency Program is a really strong approach to doing that. It combines both supportive services and counseling and also earnings incentives through the creation of escrow accounts, and that is a combination that based on 

the available information does work in terms of helping people increase their earnings. 

Like you said, HUD is considering some—has supported some 

similar proposals to strengthen the Family Self-Sufficiency Program. The AHSSIA bill that is in the House has a number of provisions that move in the same direction, and I really thank you for 

looking at this issue and looking at ways to move this legislation 

forward. 

I think one example of an important change that needs to be 

made and that all these entities are looking at is extending the 

program to the project-based Section 8 program, which is, along 

with public housing and vouchers, the third large rental assistance 

program. Currently the Family Self-Sufficiency Program is not 

available. There is no reason for that. It is equally applicable in 

project-based Section 8. And so proposals like yours that would extend it there would really do a lot of good for the people who are 

in that program. 

Senator REED. Thank you very much. 

Just a final question, because I know the Chairman has additional questions. Ms. Couch, you mentioned the National Housing 

15 

Trust Fund. From your evaluation, capitalizing this program, getting it up and running, how could it help the current crisis? 

Ms. COUCH. Well, the Nation’s housing needs, as you know, are 

overwhelmingly clustered within households with extremely low incomes, households below 30 percent of area median income. And 

the National Housing Trust Fund, as Congress designed it in 2008, 

would dedicate the majority of its assistance to households at that 

really deep income level. 

Today we have these great shortages, like almost a 190,000-unit 

shortage in New Jersey, because we are not producing housing that 

is affordable to incomes at this low of a level. We used to with public housing and project-based Section 8, but the numbers of those 

units are shrinking. The trust fund could step in and really 

produce units affordable to households at that low income level and 

also preserve other units that might be unsubsidized today and 

really set this Nation on a path toward ending worst-case housing 

needs, as HUD defines them, all of the—more than 73 percent of 

ELI households pay more than half of their very low incomes on 

rent, and ending homelessness in the United States. So we see the 

trust fund as really critical to setting the Nation on a path to end 

homelessness in the country. 

Senator REED. Let me just add one final point. There might be, 

particularly at this moment, an additional benefit, that is, putting 

people to work building rental properties, renovating rental properties. We have a very weak housing market. I know Senator 

Menendez has been leading the way on several different initiatives. 

Your legislation, which I am proud to cosponsor, is designed to try 

to get people back not only into housing but people banging nails, 

et cetera, to build housing. 

Ms. COUCH. It is certainly a jobs program as well. We appreciate 

that. And I think that, you know, the home builders have all sorts 

of great data on the numbers of jobs, both immediate jobs and longterm jobs, that can be sustained through the development of housing. 

Senator REED. You look like you have a comment, Mr. Husock, 

and I want to give you the chance. Are you all set? 

Mr. HUSOCK. If I might very briefly, with the Chairman’s permission, I wanted to add to Mr. Fischer’s comments about Family SelfSufficiency in response to Senator Reed’s question and to echo what 

Ms. Couch said about the importance of not having a rent structure 

that penalizes people for improving moving up and forward, as the 

Senator puts it, because when you have a Brooke amendmentbased rent structure that has a set percentage, the more you earn 

the more you pay, so, in effect, the marginal tax rate on our poorest 

households is higher than for our highest-income households. That 

is ridiculous. 

And so setting fixed rents and allowing people to earn more but 

to keep what they earn perhaps in the context of other requirements—with which we may not agree, but nonetheless we agree on 

that, I think—I think would be very important to promote self-sufficiency also in the context of counseling and other programs. 

Senator REED. My time is up, but the possibility exists, too, of 

sort of a shared appreciation where, you save more. But you contribute a little bit more, too. So I do not think it would necessarily 

16 

have to be either/or, either fixed or not. But I think there is a way 

in principle we can work out a formula that encourages moving up. 

Let me just thank you for that insight. It is valuable. 

Do you have a quick response, Ms. Couch? 

Ms. COUCH. I just wanted to clarify that we believe strongly that 

each household’s income should—each household’s rent should reflect its income at the time, and all of the voucher reform bills have 

included provisions which we think really encourage and allow for 

increased earned income without, you know, immediately coming 

and raising people’s rent. And so, you know, we support those proposals, but one of the key benefits of these programs is stability, 

and if your rent keeps going up but for some reason your income 

goes down, these programs are not providing the assistance we 

need them to. And so the rents absolutely have to maintain this 

Brooke standard of fluctuating as a household’s income fluctuates. 

Senator REED. Well, thank you very much for your insights. 

Thank you, Mr. Chairman. 

Chairman MENENDEZ. Thank you, Senator Reed, for your leadership in this field. 

Let me ask a few other questions here. There are various legislative proposals that would enact a stable voucher renewal funding 

policy. Currently congressional appropriators set a voucher renewal 

funding policy each year, which I am told makes it very difficult 

for housing authorities to plan for the year ahead. In addition, 

there are various legislative proposals that would clarify how much 

money housing authorities can hold in reserves for a rainy day 

without those funds being taken back or offset, so to speak. 

Mr. Fischer, you write in your testimony that these voucher 

funding rules will allow housing authorities to serve many more 

families with the same amount of funding. Can you explain how 

the predictability and clarity provided by those simple changes 

would translate into more families served? 

Mr. FISCHER. Sure. When agencies are able to predict how much 

money they will have and also how much funding they will have 

in reserves, it can let them manage their funds more predictably. 

There is history behind this where there was—starting in 2003, 

there has been a series of changes in the funding formula. It has 

gotten somewhat more stable in recent years, but during that period we saw the percentage of agencies’ vouchers in use drop from 

around 97 percent down to 92 percent, which translates to about 

100,000 fewer families being assisted. And part of this was just 

that it was much harder to predict both what funding level agencies would get and whether their funding reserves, whether they 

could keep funding reserves or those would be recaptured. And 

those played a role in those large numbers of families not receiving 

assistance. I think stabilizing the funding formula, like SEVRA and 

AHSSIA would do, would give agencies more certainty and would 

help them assist more families. 

Another sort of specific thing in both bills that would contribute 

to this is a provision that would allow agencies to assist more families than their authorized number if they had funds available to do 

this. Right now, agencies, even if they are sitting on unused money 

and have reserves, they are not allowed to go above their authorized voucher cap. They are penalized for that, and they do not get, 

17 

it affects their funding for the following year. Under SEVRA and 

AHSSIA, agencies could use those extra funds to assist more families, and this would mean not only more families getting help but 

also the agencies would have a strong incentive to reduce the cost 

per voucher because they would know that they are able to do that 

and stretch their funds further and they can help more families. 

Chairman MENENDEZ. Let me go back to you, Mr. Kinard, on a 

different issue. I am concerned nationwide but certainly that New 

Jersey’s stock of federally assisted affordable housing is aging rapidly. We have long been a population center. Affordable housing 

was built many decades ago and is now in danger of becoming obsolete as a result of a lack of funding for modernization. And I am 

hopeful that HUD’s Rental Assistance Demonstration will serve as 

an effective tool to preserve affordable housing in New Jersey and 

nationally. But I share the concerns that have been raised by affordable housing advocates that the lack of funding for RAD will 

prevent the housing developments with the greatest capital needs 

from participating in the program. 

Could you discuss whether you believe the new RAD authorizing 

language and the authorization for appropriations contained in the 

most recent, I think it is an April draft of the House’s Affordable 

Housing and Self-Sufficiency Improvement Act would help open the 

program to developments most in need? 

Mr. KINARD. Certainly. It is our belief firmly that it would, that 

RAD is an important initiative that ultimately would allow the conversion of much needed deteriorated and distressed public housing 

into a more stable environment on the project-based voucher side. 

In fact, in Newark right now we are in the midst of converting a 

220-unit public housing building into project-based voucher. We 

have been able to partner with a private bank and generate nearly 

$30 million to go into a building that—we talk about the future— 

maybe in 5 or 8 years this building would have become obsolete, 

and those seniors would likely had to have been moved out of the 

building. 

So we know that putting money in RAD will supplement in some 

regards, in some jurisdictions, the funds that are ultimately needed 

to make their projects work. Is it enough? Clearly not in certain jurisdictions. But putting money into it in the demonstration program will make some jurisdictions who are one side of the fence 

able to get on the other side of the fence and actually participate. 

And hopefully it will demonstrate a program that will generate 

more funds, will demonstrate the need for more funds, and allow 

us to get even more housing authorities involved. 

But I think there is a lot of training and technical assistance and 

evaluation that those funds will also support that need to occur 

with the RAD conversions. 

Chairman MENENDEZ. All right. So let me move to Moving to 

Work. You had a time in the Pittsburgh Housing Authority, which 

had a Moving to Work Demonstration project, and you are now at 

the Newark Housing Authority, which does not have a Moving to 

Work Demonstration project. So I think you are in a unique position to talk to us from both perspectives. Can you speak to the good 

and the bad as you see it? 

18 

Mr. KINARD. Well, the good was Pittsburgh with Moving to Work. 

The bad is Newark without Moving to Work. It is a very different 

environment, and it actually gets even down to the depths of the 

work culture. When you have Moving to Work, you tend to think 

about problems as any corporation would think about a problem 

that they are facing. You tend to think about your funding as a 

source to solve problems and create new housing for the homeless, 

create self-sufficiency programs, preserve expiring use housing 236. 

236’s do a number of innovative initiatives that the community 

that you operate in is actually desperately needing. 

When you do not have Moving to Work, you are really focused 

on trying to score your best on some PHAS or SEMAP score sheet 

or getting all your forms in because, really, that is the bar. You are 

operating in a very limited box, and unfortunately, many times you 

can see the light at the end of the tunnel and the trouble heading 

your way. But you can only move so far left and right in a nonMoving to Work environment, and you have to let the car run over 

you. 

So, you know, that is—in essence, I think the importance of Moving to Work is it will allow us to move more fluidly and flexibly 

in an environment of limited funding, and it will allow us to find 

greater administrative cost savings and hopefully serve even more 

families in quality housing. And it has been proven. I mean, Moving to Work has been out there. We were in it in Pittsburgh in 

1998, and we were able to do some really innovative things on the 

self-sufficiency side, on the housing production side, really, really 

creative things. So it has been proven to work, and I think it is a 

program that really merits strong consideration, deep expansion, 

and obviously taking into consideration some of the concerns of others. 

Chairman MENENDEZ. Let me broaden the question. I wanted to 

get your perspective because you have been in both environments. 

So I will open it to anyone on the panel who wants to have an opinion. 

We have long debated whether or not HUD’s Moving to Work 

Demonstration should be expanded and made permanent, and I 

can see the attraction from a director’s position. The question is 

whether that is the way in which we take you out of the straitjacket that you are in or whether the actual program is positive in 

terms of results at the end of the day that would want to expand 

it. I am talking about beyond the straitjacket of how you have resources to deal with your challenge. 

This issue has actually been a sticking point preventing us from 

moving ahead on the substantial set of changes that HUD’s rental 

assistance programs that we can agree on. So I am encouraged to 

hear that the stakeholders—many groups have come together 

around a compromise solution which would pair an expansion of 

some elements of the Moving to Work Demonstration Program with 

tenant protections and a strong evaluation component. Can you discuss the compromise, which I understand is incorporated into the 

latest version of the Affordable Housing and Self-Sufficiency Improvement Act, and whether it is acceptable to you and the organizations that you represent? And if so, why? And if not, why? Anyone who wants to comment. 

19 

Ms. COUCH. I will start. We have opposed, strongly opposed Moving to Work expansion for many, many years and got back to the 

table on Moving to Work last winter and sat down with most of the 

groups at this witness table and several others and HUD to work 

out what we call the ‘‘stakeholder agreement.’’ The agreement 

would expand Moving to Work’s footprint substantially. Right now 

there are about 35 agencies that are considered MTW agencies. 

The agreement would expand a basic version of Moving to Work 

to 500,000 units of public housing and vouchers, and under basic, 

the Moving to Work agencies would have what I see as really broad 

flexibility administratively to funge money between the public 

housing and voucher accounts, to reporting requirements to HUD, 

simplification of rent setting, not rent reforms, and have a lot of 

really administrative simplifications, many of which, you know, we 

have talked about over the years as part of the voucher bills. 

But the stakeholder agreement and what was included in the 

April 13th version of AHSSIA would also include an enhanced 

MTW whereby up to 25 housing authorities could access this enhanced authority where they could enter into programs that maybe 

would institute work requirements or time limits, or huge rent policy shifts that would divorce people’s rents from what their incomes 

are. And all of those, you can see the problems for tenants in each 

of those, but the bill language would also require really strict reporting and evaluation requirements and a stakeholder advisory 

committee that would try and watch and make sure that no harm 

was being done but that successful programs could be replicated in 

the future. And there are a lot of tenant protections and assuredness that households—that significantly the same number of 

households would continue to be served. 

And so all of those things are dangers in the current MTW landscape that I think would be addressed by the stakeholder agreement. 

Chairman MENENDEZ. Anyone else? 

Mr. HUSOCK. I think that Ms. Couch’s remarks demonstrate why 

it is a compromise, and some of the potentials that concern her are 

exactly what I think makes the bill attractive to those who are concerned about the open-endedness of housing assistance and not 

conforming to the goals that Senator Reed enunciated of moving up 

and moving forward. 

So in the context of a rigorous evaluation, could work requirements or time limits be draconian and drive people into homelessness if they do? Well, that would be a bad thing, and we would 

have to know about that. Could it encourage, as we have seen in 

some housing authorities, improvement in the situation and making room in a limited number of unit universe, because entitlement 

is not a likely prospect anytime soon, assistance for others who are 

on the waiting list? That seems to be worth trying in a relatively 

confined context in an atmosphere of evaluation. 

So that is what makes it an attractive compromise, and I think 

if those aspects of it were not included, you would not see the same 

buy-in. 

Chairman MENENDEZ. Mr. Fischer. 

Mr. FISCHER. Like Linda, we have had strong concerns about expansion of Moving to Work under the current rules. One issue is 

20 

the elimination of a lot of key tenant protections that would, for example, get rid of the guarantee that tenants would pay affordable 

rents that Linda and Senator Reed were talking about earlier. Because it allows shifts of funds from the voucher program to other 

purposes, when we have looked at data on the program today, one 

of the things that has resulted in is many fewer families receiving 

assistance per dollar of Federal funding, and that is a concern 

when the resources are already very limited for housing assistance. 

Another really strong concern is that Moving to Work is funded 

as a block grant under the existing—it goes from the existing housing voucher system where funding is based on the actual cost of 

funding a particular number of units. Instead, it is a fixed block 

grant amount. 

When we look at other housing assistance or HUD programs that 

are funded as block grants, what we see is that they tend to erode 

or see cuts over time in a way that the Housing Voucher Program 

has not experienced, and I think a big part of the difference is 

these funding programs, for example, the four largest HUD block 

grants have seen their funding erode by 38 percent in inflation-adjusted terms over the last 10 years, where funding for the Housing 

Voucher Program has seen some shortfalls but it has basically kept 

up with the need. And so that is another big concern about MTW. 

The agreement that is in the House bill contains a lot of protections that reduce these risks. I do not want to overstate it. I think 

we still see some significant risks in that bill on all of those areas 

that I mentioned. But in our view, the core reforms that are in 

SEVRA and AHSSIA are so important and so beneficial and the restrictions in the House agreement are strong enough that our view 

is that the package together is worth enacting if that is what it 

takes to get those core reforms. 

Chairman MENENDEZ. Ms. Hovdestad. 

Ms. HOVDESTAD. Yes, NAHRO has been working with the Department to expand the Moving to Work Program. The concern 

that we have is that there is no harm done to the current Moving 

to Work agencies and their agreements with the Department. Moving to Work as a separate bill would be OK, but our preference 

would be to expand the MTW program as soon as possible. 

Chairman MENENDEZ. Well, very good. I think that that gives us 

a good sense of where we are at. Hopefully we can move here because I get the sense that our continuous delay here is creating 

consequences at the end of the day, and moving would have a powerful, beneficial benefit. So I am hoping that this hearing and the 

foundation that we have laid here assists us in the fall to see if 

there is a possibility. 

With that, I appreciate the testimony of all of you. The record 

will remain open for 1 week so that everybody can submit their 

comments, Members can submit their questions. If we do have 

questions and we send them to you, we ask for your speedy response so we can close the record as soon as possible. 

With that, this hearing is adjourned. 

[Whereupon, at 11:05 a.m., the hearing was adjourned.] 

[Prepared statements, responses to written questions, and additional material supplied for the record follow:] 

21 

PREPARED STATEMENT OF CHAIRMAN ROBERT MENENDEZ 

Local public housing agencies across the Nation face an existential threat. The 

current Federal budget crisis looms over a public housing inventory that is already 

stressed by inadequate appropriations and the famously burdensome HUD regulatory regime. The high-water funding mark for FY2013 appropriations is now 

known. House and Senate appropriations bills are strikingly similar and both significantly underfund the Public Housing Operating Fund and the Capital Fund. 

Only deeply committed authorizers can significantly improve conditions in current 

public housing funding by passing legislation that improves local flexibility, spurs 

revenue growth and lets agencies take advantage of cost-efficiencies that are within 

easy reach. 

Public housing is, in the words of the HUD Secretary ‘‘an irreplaceable public 

asset that must be preserved.’’ That asset serves among the poorest households in 

more than 3,000 communities, both large and small, all across the country. Public 

housing is community owned, place based, and locally accountable. It provides stable 

homes to more than 2 million people every day of the year—and has served untold 

millions more over the last 75 years. Public housing has survived rapid neighborhood change and every sort of policy direction prescribed by Washington. It endures 

because hundreds of thousands of elderly and disabled households will always have 

need for safe, secure, and decent homes in their neighborhoods. Public housing will 

also endure for the more than 800,000 children whose parents need the time and 

services of a secure platform to prepare for better, stronger lives. As you know, public housing is easily maligned by occasional glaring headlines and is too often targeted by outdated stereotypes. The truest story of public housing, however, is one 

of safe and well-run housing that provides a real sense of community and that has 

quietly helped produce generation after generation of productive citizens including 

members of Congress and the Supreme Court, business leaders, schoolteachers, elite 

athletes, soldiers, artists, and public servants. 

Authorizers in the 112th session of Congress have real opportunities to pass legislation that will limit the loss of units as a result of chronically low funding and 

enormous amounts of deferred capital improvements. If the public housing inventory 

is to be salvaged for the next generation, it will need a broad menu of funding opportunities that can begin to address the enormous $26.5 billion capital needs backlog that threatens it. This authorizing Committee and its counterpart in the other 

chamber have the ability to set public housing on a new, more streamlined and sustainable course by passing key pieces of legislation. They include: 

Affordable Housing and Self Sufficiency Improvement Act (AHSSIA) is proposed 

legislation that promises to deliver long-awaited and much needed reforms to the 

Section 8 voucher program. Voucher agencies are particularly stressed as Congress 

has failed to provide adequate administrative fees for the program that is uniquely 

rule-bound and labor intensive. With no ability to adjust to these real-time marketplace conditions; HUD continues to apply SEMAP, the program’s report card, as if 

agencies were fully funded and fully staffed. AHSSIA offers agencies administrative 

flexibility that will help provide some cost-cutting opportunities. Agencies will have 

fungibility for their Operating and Capital funds and the flexibility to do risk-based 

scheduling for physical inspections. Agencies will also be able to perform fewer recertifications for fixed-income households and to use a more streamlined rent and 

income determination process. Overall the bill allows agencies to economize on costs. 

The bill was gingerly crafted with tenant advocate groups so it has some added complications. For example, the bill allows agencies, for the first time in 14 years, to 

charge a higher minimum rent of approximately $70. The opportunity for added revenue comes with new reporting and procedural requirements. 

Of special importance is the section of AHSSIA entitled ‘‘Flexibility for High-Capacity HAs’’ that makes permanent the highly useful and successful Moving to Work 

(MTW) program. The bill also allows for a significant expansion of the program but 

limits participation primarily to PHAS and SEMAP high performers. A Moving to 

Work (MTW) expansion was recommended in HUD’s own 2010 interim MTW report 

to Congress. The report stated ‘‘MTW provides unprecedented insight into alternative methods of providing housing assistance. By prolonging and doubling the 

number of participating agencies, the housing industry stands to learn even more 

from this unique resource.’’ This successful program has survived for 16 years in 

spite of unfounded criticism of the MTW demonstration. This section of the AHSSIA 

consumed much of the bill’s negotiations and added more narrow definitions of 

households served by MTW. The enormous transformative efforts in cities like Atlanta, Chicago and Philadelphia might not have happened if baseless fears had been 

allowed to rule implementation of the MTW demonstration. MTW is the most hopeful preservation solution for the greatest number of agencies at HUD’s disposal. The 

22 

program can help counter the deep and chronic funding shortfalls in public housing 

programs. To date, MTW agencies have used the program’s flexibility to significantly expand affordable housing opportunities in their communities. 

Also included in AHSSIA is $30 million in funding for the Administration’s RAD 

(Rental Assistance Demonstration). RAD is the Administration’s signature program 

to help housing agencies convert their public housing properties to a more reliable 

Section 8 funding platform using either project-based vouchers or project based rental assistance. Appropriators launched RAD in the FY2012 THUD Appropriations bill 

but provided no new funding for the program. The bill allowed agencies to convert 

with only the money currently available to public housing properties. Unfortunately, 

the current low funding cannot sustain properties in the public housing program— 

much less support them in the Section 8 program where higher rents are needed 

to maintain properties and to also support debt service on financed capital needs. 

The $30 million will make it more likely that properties with deferred capital needs 

will be able to participate in the RAD program. 

Today public housing finds itself at a critical juncture where poor funding might 

well determine the fate of the program. The Subcommittee has an opportunity to 

intercede on behalf of public housing and its residents by working with the House 

to pass AHSSIA this year. Public housing has been rocked by a series of recent 

funding and policy choices that call into question the Federal Government’s resolve 

to continue its decades-long relationship with local communities to house the poorest 

among us. It is well within the authority of this Subcommittee to pursue proposals 

like AHSSIA, with its important MTW and RAD components, that will help preserve assisted and public housing for future generations of needy elderly, disabled, 

and family households. PHADA looks forward to working with the Subcommittee to 

find new ways for agencies to use flexibility, streamlining and innovation to bring 

additional funding resources to support and maintain public housing. 

PREPARED STATEMENT OF KEITH KINARD 

EXECUTIVE DIRECTOR, NEWARK HOUSING AUTHORITY, ON BEHALF OF THE COUNCIL

OF LARGE PUBLIC HOUSING AUTHORITIES

AUGUST 1, 2012 

Chairman Menendez, Ranking Member DeMint, and Members of the Subcommittee, my name is Keith Kinard and I am Executive Director of the Newark 

Housing Authority and Board Member of the Council of Large Public Housing Authorities (CLPHA). CLPHA is a national, nonprofit membership organization that 

works to strengthen neighborhoods and improve lives through advocacy, research, 

policy analysis, and public education. CLPHA’s members comprise nearly 70 of the 

largest Public Housing Authorities (PHAs), located in most major metropolitan 

areas in the United States. These agencies act as both housing providers and community developers while effectively serving over one million households, managing 

almost half of the Nation’s multibillion dollar public housing stock, and administering nearly one quarter of the Section 8 Housing Choice Voucher program. 

The Newark Housing Authority (NHA) has over 11,000 public housing and housing choice vouchers. NHA is the largest public housing authority in New Jersey and 

one of the largest in the Nation. We have a portfolio of 44 public housing communities with a total of over 7,000 rental units scattered throughout the City of Newark. NHA also administers up to 4,000 Housing Choice Vouchers (Section 8) within 

the city limits. A unique aspect of the Newark Housing Authority is that the agency 

also serves as a redevelopment authority and uses that power to enhance the renaissance of Newark. As a redevelopment authority, the NHA has a stake in the creation and maintenance of safe, livable neighborhoods and the expansion of economic 

opportunities in their communities. 

We thank the Subcommittee for holding this hearing on ‘‘Streamlining and 

Strengthening HUD’s Rental Housing Assistance Programs’’ and appreciate the opportunity to comment on those matters that we believe are critical to include in any 

legislation to improve and reform HUD’s rental assistance programs. As you know, 

for many years, CLPHA has been active in these legislative efforts. 

We have most recently been engaged in efforts to improve the draft legislation entitled, ‘‘Affordable Housing and Self-Sufficiency Improvement Act of 2012’’ (AHSSIA) 

in the U.S. House of Representatives. AHSSIA is the latest iteration of recent endeavors to reform and advance the Section 8 Housing Choice Voucher program 

which began in the 109th Congress and continued with the ‘‘Section Eight Voucher 

Reform Act’’ (SEVRA) and the ‘‘Section Eight Savings Act’’ (SESA) through the 

110th and 111th Congresses. While we have seen different variations on a theme 

23 

with the various legislative proposals—with refinements and degree of emphasis— 

there have been certain core components in most versions of the reform proposals. 

Included among those core features which CLPHA strongly supports are simplification of rental assistance administration; preservation of the housing stock; protection of tenants; and expansion of funding flexibilities and local decision making for 

housing authorities. 

As CLPHA testified last year on SESA, we believe that simplifying and streamlining the administration and funding of the Housing Choice Voucher (HCV) program is a key component to a broader rethinking of the landscape of public and assisted housing in this country. Equally, we believe that expansion and permanency 

of the Moving to Work (MTW) program is an essential element in strengthening the 

flexibility and local decision making that housing authorities need to be successful 

in their communities. And, we believe that the Rental Assistance Demonstration 

(RAD) program will be critical in helping housing authorities reposition and 

strengthen an effective housing rental assistance delivery system for residents in a 

time of shrinking Federal budgets. 

Streamlining and Simplification 

Voucher Renewal Funding 

One activity to streamline and simplify would be a permanently authorized renewal funding formula which would provide predictability and stability to the Housing Choice Voucher program. As you are aware, the shift to the ‘‘snapshot’’ voucher 

funding formula in 2004 caused a serious mismatch between funding eligibility and 

vouchers requiring renewal funding. Further, continued uncertainty about determining eligibility each subsequent year undermines agencies’ ability to manage 

their programs efficiently, as they are unable to predict the level of voucher utilization that they could support. We have seen, since 2007, how funding based on actual 

leasing and costs provides agencies the resources needed to increase leasing and 

help additional families. We are slowly recovering vouchers lost to the previous policies. With a renewal formula reflecting actual PHA needs placed in permanent statute, rather than in annual appropriations acts as is currently the case, PHAs will 

have renewed confidence in the predictability of their funding. A stable and reliable 

funding formula will provide predictability for housing authorities and landlords 

alike. They will be able to plan for the future, taking steps to increase utilization, 

reduce costs, eliminate inefficiencies, and improve service delivery. 

Reserves and Use of Funds 

Another proposal that we support is to allow housing authorities to retain a portion of their housing assistance payment funds as reserves. An adequate and stable 

reserve is the bedrock of any well-run enterprise. Housing authorities serving large 

metropolitan areas must often deal with fluctuations in the number of landlords, the 

cost of rent, and other market factors beyond their control. We recommend that 

agencies always be able to retain their full accumulated reserves in order to support 

leasing in their communities, to allow them the flexibility to respond to changing 

markets, and to prepare for planned and unplanned extraordinary expenses, particularly in light of Federal budget allocations oftentimes subject to pro-ration. 

Given their level of unspent funds, some PHAs have taken steps to increase their 

voucher utilization levels. They have made commitments in their communities to increase leasing by a certain percentage or house a certain number of additional families. Large funding offsets and pro-rations could derail such plans, even if a housing 

authority is making progress toward their goals. Housing authorities that have defined plans should be allowed additional reserves protection to increase leasing. 

The Newark Housing Authority has been struggling with voucher utilization 

issues for more than a decade. Newark’s Section 8 program consistently spends in 

excess of 100 percent of the allocated Housing Assistance Payments (HAP) funds; 

however, we report less than 80 percent utilization on a monthly basis. This discrepancy is due in part to the high cost of rent in the region and an offset of 10 million 

dollars of reserves. The reserve offset occurred in the midst of a plan to place 2,000 

families on the program and created community animosity and trust issues for the 

Agency. 

Additionally, agencies participating in the Moving to Work (MTW) program 

should be funded according to their agreements, subject to any pro rata adjustment. 

MTWs rely on their reserve balances as set out in their plans and agreements to 

leverage funds for redevelopment and revitalization projects. Allowing their funding 

to be offset by their reserves would severely undermine the goals of the MTW program. HUD has recognized this fact by exempting MTW voucher funding from offset 

provisions to meet Congressionally mandated rescissions (see, PIH 2009-13, PIH 

2008-15). CLPHA supports language in previous versions of SEVRA that clarifies 

24 

that MTW agencies shall spend their reserves in accordance with their program 

agreements. 

Finally, CLPHA has long advocated eliminating the authorized-voucher cap on 

leasing, and we strongly support provisions that allow leasing in excess of authorized levels. 

Project-Based Vouchers 

CLPHA also supports previous legislative provisions that allows housing authorities to project-based vouchers in their own buildings, as part of a public housing redevelopment, without going through a competitive process. This would eliminate a 

significant administrative burden that has, in the past, kept PHAs from being able 

to commit project-based vouchers in a timely fashion. Time is often of the essence 

in redevelopment deals, and having this provision would facilitate and expedite 

project-basing of vouchers. Thus, this provision would not only help increase the affordable housing supply using tenant-based resources, but also add to the supply of 

deeply subsidized hard units for communities that need them. 

Newark’s experience with this policy is two-fold. We currently own a 100 percent 

project-based voucher, elderly/disabled hi-rise building that has been thriving for 

many years. This facility has benefited tremendously from this initiative in many 

ways. The most prominent benefit is what it provides for the residents. Through 

Project-Based Vouchering the agency has been able to take on extensive capital 

needs of the building and upgrade the general amenities for the residents. Our second experience involves our current work to convert a public housing, 220-unit, elderly/disabled hi-rise building into a Section Eight Project Based facility. We started 

this process 4 years ago and quite frankly we are about 70 percent through the conversion. A significant amount of administrative time and financial resources have 

been used to competitively procure and ultimately award project based vouchers to 

ourselves. In Newark, Section 8 vouchers are scarce and we were not able to provide 

any vouchers to the more than twelve (12) applications who submitted proposals. 

Everyone’s scarce resources could be better utilized. 

We also strongly urge the Subcommittee to expand the flexibility of PHAs to use 

project-based vouchers to leverage private investment for the preservation of affordable housing. Specifically, we support increases in the percentage of its Section 8 

vouchers that a PHA may use for project-basing, above the 20 percent cap, and in 

the number of vouchers that may be project-based in individual projects, for the purpose of preservation. There is precedent for these changes under the recent notice 

implementing the Rental Assistance Demonstration, which exempts converted units 

from the 20 percent cap and increases the percentage of vouchers that may be 

project-based in a single project, though we do not believe that the Department has 

gone far enough on this second point. Again, project-based vouchers have become 

an essential tool for PHAs’ efforts to meet their local community needs, particularly 

with populations that require the availability of ongoing supportive services. Increasing the resources that can be used for this purpose can play an important role 

in preserving affordable housing and efforts to end homelessness and serve other 

vulnerable populations. In addition, we support the language in the bill that would 

extend the maximum term of the Section 8 contract from 15 years to 20 years, 

which will also encourage private investment. 

Administrative Streamlining 

Some changes that could streamline administrative processes include: options for 

triennial recertifications for fixed-income households and moving to less frequent inspections and interim recertifications. The Newark Housing Authority spends a 

large percentage of administrative fees on work associated with mandatory annual 

recertification, annual unit inspections and rent, allowances and asset calculations. 

Local flexibility that maintains the integrity of the program while eliminating the 

need for high cost, low benefit work could save our agency vital resources. It is 

worth noting that many similar innovations have already been tested for years at 

MTW agencies throughout the country. Many MTW agencies have adopted less-frequent recertifications for their fixed-income households and have found that it not 

only produces less stress for their residents, but also significantly reduces their administrative burden. 

Some MTW agencies have been able to streamline their inspection process, grouping inspections geographically to save travel time and costs. Allowing housing authorities to use a risk-management approach to conducting inspections, rather than 

tying them to arbitrary annual deadlines, will help relieve housing authorities of a 

sometimes redundant administrative burden, while still ensuring that families are 

housed in safe and decent housing. Also, allowing housing authorities to rely on inspections from governmental agencies further simplifies a complicated inspection 

25 

process and allows localities to rely on one standard for guaranteeing the suitability 

and safety of area housing. CLPHA previously testified in support of these changes 

in SEVRA and SESA. 

Additional ways of streamlining administrative processes and reducing administrative burden and costs include additional simplification of the rent calculation 

process (even beyond what is included in SESA), allowing flexibility with regard to 

re-inspections, and allowing the development of local wait-list policies. These are all 

areas in which Moving to Work agencies have been developing local policies, to meet 

their statutory objective of ‘‘reducing cost and achieving greater cost effectiveness 

in Federal expenditures.’’ Congress would do well to look to MTW agencies for further ideas about administrative streamlining. 

Rental Assistance Demonstration (RAD) 

CLPHA’s objective for a rental assistance demonstration was straightforward. As 

MTW helps housing authorities in their public and affordable housing preservation 

strategies, we were seeking to preserve the existing housing stock through the funding flexibility and funding leverage that MTW offers. For this reason, we proposed 

and supported the Rental Assistance Demonstration (RAD)—a conversion option for 

public housing rental assistance to project-based vouchers (PBV) or project-based 

rental assistance contracts (PBRA) that will enable greater funding flexibility and 

leveraging. CLPHA worked alongside other stakeholders to help Congress enact 

RAD last year as a demonstration program to preserve this important affordable 

housing stock. 

We see this initial version of RAD as the first step in converting public housing 

subsidies to leverage additional capital investment and address the nearly $26 billion capital backlog of our public housing stock. The current no-cost model that authorizes conversions to PBV and PBRA is an important step forward, but will only 

go so far in addressing a segment of the portfolio. Furthermore, a recent industryfunded research report by Recap Real Estate Advisors makes clear the critical need 

for adequate RAD funding in order to provide conversion and recapitalizing opportunities to a larger pool of public housing properties. 

With no funding to support this first iteration of the demonstration, CLPHA appreciates the broad waiver authority from Congress to create the best program possible within the constraint of current public housing operating and capital subsidies. 

We believe this waiver authority is a critically important tool in order to ensure a 

successful demonstration program, and HUD should exercise its waiver authority to 

a greater extent than it proposes in the recently published Final Notice. In order 

to operate successfully under the no-cost RAD program and for housing authorities 

to be creative in their approaches, this flexibility is necessary. For example, the limitations on PBV conversions, including contract rent setting, the cap on the number 

of PBV units in a project, and the 12-month choice mobility constraint, all create 

a disincentive for housing authorities to pursue PBV conversions and undermines 

a critically important option in the demonstration program. 

The current House AHSSIA draft proposal includes the original legislative draft 

language from the stakeholders’ coalition on RAD. It authorizes a demonstration 

program for the voluntary conversion of units currently assisted under the public 

housing or Section 8 moderate rehabilitation programs to a contract under either 

the Section 8 project-based voucher or project-based rental assistance programs, including the authorization of appropriations of $30 million per year for 5 years of a 

demonstration. The additional funding is for supplemental costs of the first year of 

assistance, evaluation, technical assistance to housing authorities and tenant organizations, and other appropriate purposes. 

It also authorizes properties assisted under the rent supplement program or the 

Section 236 rental assistance program to convert to project-based Section 8 renewal 

contracts, subject to the terms of Section 534 of MAHRAA, with authorization of appropriations of $10 million per year for 5 years. 

CLPHA strongly supports the RAD program and considers it an important tool 

for public housing preservation strategies. The additional funding authorization will 

help PHAs stabilize properties in markets where the current level of assistance and 

rents are not sufficient to address capital backlog needs and provide for long-term 

viability of the properties. We support the version of RAD in the AHSSIA bill, and 

strongly urge the Senate to include the RAD program in any legislative proposal. 

Moving to Work Expansion 

CLPHA has long been a strong supporter for a permanent expansion of a Moving 

to Work (MTW)-like program for any interested housing authority. The premise of 

MTW is simple, to allow PHAs to develop locally driven housing plans that respond 

to local housing needs, in concert with their residents and community stakeholders. 

26 

The current 35 MTW agencies administer over 131,000 public housing units and 

307,500 Housing Choice Vouchers, or more than 12.5 percent of the current traditionally PHA-operated housing stock, in addition to operating local housing programs that fall outside the bounds of traditional models. A review of the current 

MTW agencies show that they have raised the standard of housing services, used 

program flexibility to create jobs, added affordable housing stock, served more 

households, and helped families build savings. They have also shown how to operate 

and manage affordable housing in ways that is accountable to their residents and 

local communities without needless and time-consuming bureaucratic measures that 

add costs but no value. Many administrative activities now universally accepted as 

good practice, providing cost-savings, are beneficial to residents, and are noncontroversial were first tested in the laboratory of Moving to Work (MTW). 

Instead of asking themselves ‘‘what do we need to do to make sure we score high 

on our next Section 8 Management Assessment Plan (SEMAP)?’’, MTW agencies ask 

themselves, ‘‘where are the most profound needs in our community and what are 

we going to do to address them?’’ This fundamental shift in thinking has allowed 

MTW agencies from Cambridge, MA, to Atlanta, GA, to Seattle, WA, to solve problems in their communities more efficiently, more rapidly and with greater community participation than most non-MTW agencies could even imagine. 

The strength of MTW is that it allows PHAs to customize their services to meet 

the unique challenges their communities face. For example, in the northwest and 

northeast, MTW PHAs are engaging with homeless service providers in ways unimaginable outside of MTW. The new sponsor-based housing is allowing the most 

difficult-to-house populations to find stable homes, with supportive services. Comprehensive, long-term services are being paired with PHA redevelopment efforts to 

create dynamic, place-based service centers where the most vulnerable households 

receive not just housing, but the intensive supports they need to keep from slipping 

back into homelessness. These are just a few examples of the amazing work going 

on at MTW agencies. 

NHA is not designated as an MTW agency, however, in my previous role as Executive Director of the Pittsburgh Housing Authority, we were among the original 

group of agencies granted this broad range of flexibility. Having worked for 14 years 

under both circumstances, it is evident that the greatest advantage of MTW is the 

localized focus true regulatory flexibility affords. For example, in Pittsburgh we 

were able to utilize MTW to dramatically improve our housing stock, promote significant private investment, streamline our applicant waiting list process, promote 

programs for the homeless and create a social service endowment to consistently 

fund strong self-sufficiency programs. 

On the other hand, without MTW in Newark, our focus has been predominately 

driven by regulatory scoresheets such as the Public Housing Assessment System 

(PHAS) and SEMAP. With both limited flexibility and funding, we spend more of 

our time focused on the timeliness of our PIC submissions, Asset Management 

Projects (AMP) and Central Office Cost Center (COCC) performance (financial performance of the central office and grouped sites), Voucher Management System 

(VMS) submissions, coordinating REAC inspection activities, along with dozens of 

other monthly, quarterly, and annual submissions. 

In sum, if the Newark Housing Authority were designated a Moving to Work site, 

we would seek to create housing programs for the homeless, focus on prisoner reentry and transitional housing. In addition, we would tackle extensive applicant 

wait-list issues and examine rent simplification, recertification and inspection processes for overall program efficiencies. Finally, we would utilize funding fungibility 

to create greater housing opportunities for our city’s most vulnerable populations. 

However, we are aware that the MTW program is controversial among many 

housing advocates and engenders strong, negative, and emotional reactions due to 

misperceptions and misinterpretations of the program’s objectives, accounting, and 

results. Given the disparate views of proponents and critics of the program, we realized the best approach to try to resolve differences was to declare a period of detente, sit down with the differing parties, and attempt to work out a practical agreement on extending and expanding the program. The result was intensive, passionate, and focused deliberations between the stakeholders. 

The stakeholder group representatives included tenant advocates, civil rights advocates, housing authorities, assisted housing owners, and HUD. In a remarkable 

undertaking with no issue too minor or nuanced for consideration, the stakeholder 

group produced a set of guidelines culminating in the ‘‘MTW Expansion Principles 

and Proposals’’, along with a legislative draft incorporating those guidelines, that 

was agreed upon by all the parties involved. The stakeholder agreement provides 

for a permanent basic and enhanced MTW program; a robust evaluation; new development tools; and resident protections. 

27 

Included with my written comments for the record is a copy of those principles 

(Attachment 1) and legislative draft (Attachment 2). 

Closing 

In closing, even as we work to improve the housing choice voucher program, we 

must not forget the continuing challenges faced by the shortage of public and other 

affordable housing. There is still an urgent need to preserve and increase the supply 

of housing units specifically dedicated to those most in need. Once again, CLPHA 

urges this Committee to work to provide additional resources and tools to enable 

PHAs to preserve our public housing stock and increase the supply of housing affordable to very low-income households. 

We appreciate the Subcommittee’s perseverance and willingness to continue to 

tackle the reforms needed in HUD’s rental housing assistance programs. We look 

forward to working with you and HUD on making additional improvements to the 

programs and developing reform legislation. 

Thank you again for this opportunity to testify. 

28 


llmm ar~' of Moving 10 Work Proposa l 

MMlng 10 Wor\..l~tTWll>lStsl1b~sh!.'Ii in 19961D1es1lnnO'iltive III). cor admmiSlenng mll&lllouflil'lt 

programs lhat wt\Ild pel1tlilloc.tliliello b<o\ler ~ddre5l the needl (n!hell oomnlunilies by ptOIII!)Iins tl~ibilily 

Tnt ~ hI;; been I dtmonsmltloo prOitfam !in~ \h:n time. 

The proposal iqltsigned 10 in~CIfl" Oule the fu.ndamemal frtlll\.:y,«k of MH\ I~ ItIOo'll1l.Qnd «t«lllllgtl 

iMOOIltiOO by jII.Iblie hou~ng ISenQelI whilc rMunng Inal residrnl5 are nOl undul~· relll bur4rnro. TIP: ~I 

would ?rtJlide elm eligibility and admi\&iOll mien) fot housing IgtIICies along lIith solid toob 10 pm1lil the 

Imporlanl eal 'llli,,,, Df perform~ and mulli. 

U~ethe fllUl'iiiOO'lofthe CUIT'eI1t AliSSIA diSCtl~oodtali.1he MO'iing to Wor\.. PfI.l1!I'lll woold t.f mw 

pmlW1\:nl undcr 1m, prol'OSlI. Currenl ~ITW BgmCiI:! 1I()Jld COlI~nue 10 Ilpmle theil progr1ms ~ pmvidro by 

u..~r l!lIiSiing con,ra,1S fer tho """.irung I""" ofl"" ""nnoel, but 'Q"ld .<.lwM In the "new" ,\lTW pn"lSIlInl 

\l!If1!(jIIeSl. 

The 'new" MTW IOowld hhe two cOIlIpooeni5. 1) I basit M1W I"0gwn Iholl pr<1>ides h()lJ~ns 1I~~l'\o II Ith 

Ih~ ne.~ibilil}' 10 wmbine \wc!ler, I:apimllllid O{1tmlin~ funth u ",elias impirmrTIllffil limplilit:a~OI\ lilt! 

[)(her idminisnnl"e lIreamlining measures II\d 2) III '"enhancM" MTW prosam lI'WId ioclooe 1M elemenls of 

the basic "in\, 1'fI>'d3II' 001 wadd aJ!i(IJIfflllilI limitro numberul"lgt't1cies IOUl\de,t~lemlj<!f I\'!II morm 

tniUlIlVcs. \lad" I'a(!JlI'tments 100 time limiu ",iln I fo..""U'i on riS'JfWll~ u.uin!\ fhe implct\ oftheoe 

iKIi\IUes, 

To \"1lC(:oulgc i broad Tl!l~ of PIIM 10 Ijlpiy, I~nurulw:f of bQ\lling MIIboritits Illal are ~c~ro lnlO I~ basic 

"ITW ~loOOld Mlbc limited. b!J\lht n~mberDfunil> generall~ lOoould becapPed al lOO,OOO unitS; 

Ilo\'oev~, if any of the ll~ !~f);eSl huus,"~ agenCIes <If Illy e:tistinl! ,\ tTW PIIA5 JOIn Ihe prosIMII. thtilumr; 

",ruld !IIlI lffw the cap. I lousing lUloc.nties ~}'ing fOf Ihe "\"1llunccd" MTW ~lptatiOill would bc upped 

.1 25 agmcicl; t"{iSling MTW PIlAs could join Iml program l'l1\'~\1 ",fhoul coonllng tow~rtlSlhr .ap 

Prot.Cling !loIn l$i d~nl ~ Ind ftd ~1 Fund! 

The JIf~1 flITMdestlil1 only hillh capil\:iry I'IIM ",ill be~!l1ll1td 10 t1i( MTW program; ",d jlIevtJilSthe 

waivt'I oI"kf)' p«l'>'isi\)ll$ 0( I~ U.S Hrulins MI. The proposal is deslgnro 10 0II5U~ thlilhe participlllmg 

hQIJ\lng ~e; conciooe 10 St.'fVe subSlantitlly t1ie WIt numbel" of fsmiltell bell1£ ier.td roor to being 

IICCtpwd InlO the~tn\' program. bul "ilh nfxibiJity 10 &Ilow PHAs 10 ItIlljlOr.Irily u>e funds fur InajOT t:.:tpital 

Impm\·menl5. 'eM~i aOOOlht'lillinlu\·es FllIIl\er,lh.: ~ns Ij!ency liI.'ekmgtolppl) fill" Mnl' nluSthoid 

alleaSl tWl! public m~illltl' III solicit OOIltmunio/ tnd ~ident tnjll.ll, 1"r.;:bmu!l>SISlance furllis "'ill be 

!I"/lit.lblt fill" f~idem grOU!llI~ plnicipe!c in Ibe j'IIl«.Il 

An i$d\;SOf). !;Ioup ri illlert5U'd stakdtol.!m "ill be ftrmtd to wort "ith fllJD I<'l ~tabl ish m~htxIolog;~ for 

e'liIIUltlonofbolh thfba>lC and mhanC((! MnV program lIS lIell lIS iIlaJ~le fUldU1$$1lIld make 

ft'COlnmmtiati()l\$. Imeum reports from HUD win be rtqUired 

IiUD ",;u be dilectoo 10 dt!li!lllftd IIlt1'lcrnrnt enforcrnltnl nl«.itani>llIS (itK"iuding lel1tlinltillll) roo nlJI!1laJ 

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a""S<,," c'" a nd 

,h",slioldCi'it"rI" ! 

Q IX"'WIOII'Me,j ... 'pC .... "'"ce ",;,1, '''''0''0',,,,, and 

(e.g pun;ci"",if\!.l. in HOPI! VI '''- Chok" n,in!! 

''''' cr<:d,tS. J>'Inicipa'ins in rS5. an IlPC 

Jl.IIn"",ing "i,h ull,CT p,o"ide 

",,,",,,c,,,) 

... Stair Cilpadty and 

CI evidenc" "frcsidel'l and co"""""ily H"'ol""",C'" 

<) ofC(O"'l1lunity '''[';>01'1 for M'rW "ppIICJIti"', 

will, I I R 1209, "'" n ... r"",) 

o willi .... ,><In;nl,! ° In g""" ",ilh ,he illdu<ij!1S II\) ul"e""lvNI 

" air 1-' 1111";"8 or OIher 111ldinv 

<> """'I .. <> in'''n,,,1 '" m1.'!"wng'n 

dTon. that r"'ull ,n (e.g ""e1'1!lo,).,r 

",,,,oue ('" 8 _ ,-dll '''''''Que ab""" nailonai ;''''''''1I''') f<>t 'he 1'1 IA 

<> r>.la''''si"s projects Of ""lJ'IW"S i" aClivities '''''tIS "",,_I IV!) 

f;'IIlIl,nll $0\1"'<'$ . . ... cll """,Iop,ng housing e",dit. or 

"",,,rins ""0 "1lf«1ll"'''" w;,h ",hCO' tho "" "thel ", .• 

""ppor! action. 

A d,v"",,, "'''s'' of I'HAs (in terms 8<'<:I8r"pl1)'. "Ie) ",II be .... I"",,,d 

l'Of MTW. Ihi. '''.Y indude 8 difre,e,,, "', offcal",'e> Ih"r belle, 

,nli,,-,,," 'h" s",,,h RY local Dtld " " "n,pl"ymeu' 

I tUD "'''Y "1>C,,;ly f,,.- PI,tA. Ihal huvc (em",,-,y " .. ,hll' willin" '" I"" r>(Il[",r" ofint.,..,." 5ubject to ""hhe,,,,,,,,nenl 

A l'liA Sub"""",!,! R 1','(>p0';RI ",1 .. 1 hold 'wo plIblic 111"",i"S> 10 

reo:dve cun,,"e,," '''' 'he pmpn",I, includitl!! ,he in,pli""''')I1'; "fchanges "ud 

th" p"".il>l,, ""p"et "" ,.."'du

m,, Th" PI-t A In"S' I",,,'ld,, notic" to 

""d 'h" 1""",1 "on""un;,)' no In",r .hall 30 dRY" b<-fote the tirS! of Iho:: (,," 

'''hlie "",el'nll" 

Funding will be provided ror ,,,,,iden' techn'"al a ssis'an"" Rnd ""paciIY 

buildi"". <:<>nsistcnt with the I-t R_ 1209 with revision" to nddress 

, 
36 

37 


TITLE IV- HJ:XlIlIl,ln' FOR IIiGH-CAFACITV PU8L1C IIOrSISG AGE=,"CIES 

'.I<I(1(lhtIIM<liStOl .. 11coq ~'H4ImI41ll st' 1m,,"*,,! I ~~'dt.­

~ .. tb<aoJthc~,~"",." .... ,_ 

-src. J7, fLEXIBIUTI' f OR IIICII Tn' HorSISC ~C "C S. 

-''I ~nl'OSt .-C~ ~ttIi ~~'" lh(l ~('j "1lIw I~". W f"II".lIC litbl$"",UO'III .. "l ,."" .. f'I'bIi. _~~lhaIrcf .... ~<llIk"""""'_"~iJtyOlldnru.IiI) .. ~~""", 

"oil 'I1",u\e "":" •• ,,,,,"I~. "' ....... ~ """'"'" k><ahl"" ml tb< poI.1 ~ ~, ~. 

I.,... u.kt ~ ... '" pohioc ~ .~,.~ .. """ ""- r..,0hi~~ 10 ~ mol ""I......",. nI ........ """" .. 

1"''''' i'oc,"""",,,","" ~ll'xob~onol ... oIuIC .... '.n,,~~to ..... ~~ ... ,..., Ibol-

(l1_kto"""t"l'f""'!lO!"""I"'""'.,\"tt\ ....... mI<"IIlrlIl<I'''''' .. ~f ... ''''' 

oockoohn, ~"'t. ... ~ rthJh.j,I.II.., . ......ti_.~ rq>loo:ml (dIbc "'-"' • n;l.. 

,0( riI' II<..! ok\mo....., ,. """~ ...... lop"i- ocld;lO",,1 offonlobk ~lB- I"'~-.loi! 

~n. ~'" lIII_g ..... ..m.r orl..-boo """'''1IIi _-Iou" I ...... _oct "'1Io<!r~d •. 'I<"<O' 

(2) 1""'"oJ, r ........ _"" "'" ...... ...,,-00 _ 10 I_lm ., ,"' ... ...... ~-. __ ... """ . .-.!"""''1'< __ ... If--'''f'''''''''' ~M"f'IM""""'"'l 

k ... • ... """",",,, ~" ............ 111m • .., Iiuno '''', ........ tm!cft! 

-\1) "I ....... roQ.!; I ••• ~"" clf",,"~ II< ", .. -ftT~ _ _ , mcj"lu't! ,,""lo..~""'''''''Y' 

__ ,·<."""'OlI.:r .... m·lI1l~ .. ~M~ 

',4) ..... ~ ~"" F«lmL l!I ..... ad ........ hmJo., -..:~ 10<ILIIl;., h: ~~.,",_ 

M""l' to\ <min ~ .uol.~ICCIl><lllt\' 1.0",,-, PiJ jW1l1l( 1tT~ ~ 

~"'" md ~'''''' porb¢II'4'> \»111«:0. p.obh. ~l "I'<lICIc:> oaJ <mOl< jlI\>Iu.:., .. rod.!. ~ .. !ICIlLb cor, -.I akaIO)fII>~..tioo ~uJcl"m, o.lcoIlf>-~ ~ .,ldl'> 

«n);<>~1IId1lll!'«"lllOilbn .... o.!oo<O!.-Ir~ror ....... _r .. ~""; 

'"\S"! Ic!C ;limJ:o!ll~ oml">l"ll,,, ... """llIIII>l..,.,....,. """' ..... ~"'''",., ~1OdIOO! Mol 

... _ .,., k _!ioal. a.bIwu(rahl< """ "'",' .. k ... .t~ ooJ dhh,. 

iI>.'<roI"""!I"'IlJcd..~luJ<l'<\Oll."<!ldf\Q'}" ...... -IIId,""i~ IoII._r....tio!rn .. (_. 

Jm1. ~, ... """'oo:tIIIj' '1j<)'IOII"o!lIObCCI'" Id ti'l<1fl-..:u'~vf<ocll_OI". -'" \6) "'" il<I<.opol ~.,.. .. ~ c{ It>: Iuoal _~ ..J ~,1h Ill< ~ 

~".n"tool rnoltoI> 

1 1) Tl\!lIlG ANi) Ol'l'OlnUI-1TY fOIl t'OM.Il(Nl....:r ... ~ .4dII, ~ollun ~ 

...-~ It!< dOl, .... Il10",,,,_ ,4Il10 An'voIabI< I~ ftl <;"U ·liIoII"io:lent>' l""""l'!IIm( 

N;, •• !o l._~ I oIru1 _"'I"~f"~" _ Ih II>: ~"""''''C1''''" 

cod f"d"~ (Of ... d«uon ,/...,.", ~ """""""' ......... jWIIo: .. iI>c f""'Fl'".....,. .... , 

<cct"", 1,,(0'" 01 ..... 1"'" of l""I"'IjI>I'"I"""'" ~ ho-mo..k "'''' .. 12 ..... ,,( .... ...,. ,,( Ill< 

("' .. .do<!""'_I'IIIIfI.o .. y~'",.;«""""'Itno ... j ..... .....,.. .. ~\""" 

1h<X<!<"tor. ;oko/l .. OI1I.< • .nn......,"Ii!.oNc l ... pobI .. ~ 
38 


-, (Z) P'WNlSAl,'>. CRlTUIA_ ~Ie<\ooa 04'1""""" iDJn 1hI. ~ ~U be: _'11) 

"'~'ItlIIJ rw-1(,,~~,,~W! lJ'OII«JIk~'fl<>'Irl<ll ... ~""" 

1.'IOIJ_.,W(olIo).-"'l'........-. 

"(AI 11JOI1.('A/'A( lTV P1l1llI( nousu,lI A(jENCIES - 111< s..:..:..,. -4laII """'" 

"' .......... bt..u'"'1"'~...,J., rro.. !op~,~ """!><1Io ... "~.,.,... ... , ~Nt;b WlI .... , 

'"" •• ""1' ..... -

>(l)"!Ior.,..,..t. ' .. f01<w III ilS..,..,.""'" MJ I poll'" ...... 1If~ 

_ 01' II I..,. ..; ~'<III ..J IIlhtcJ "'~ tc:..!h.o ~; """"'" 01',« W .n..:.J f" 

--.. M ,.." • ., ~~I f,~ 1M ",loooIbr 'Q! ,~ 'IS J'<"'<III ,~,\.< .~ 

,-""'.01 _ 

·iu~I)Iloo' .. , ' tw.~ J'I<rlino<t.....,. .... """'''' ~--'>$I>o>I\'l""" IJIIh: 

'P' a.I!nm!<I<r> pltllio: ...... ,) aI tOe Il«ld 8 _~.........,. 1"''''''' 

j,Ilh<,._1 """'"",...."cloc:r ...... « .... ~) .. 

-III) I""" NO_ l!i Idm" ...... """" Ill< f"tIIo\ ......,._ ')'-«111 M.l >kt _ g _p<'In<III_~"" ~ '"'.,.,...... ~\t!l ... 1ou 

...... """"' ....... ~ '~"''''f''<l1<'''''>bttI"><J~ il:Io:~ b-l ". <M"" ~ ~ . .. Ill", ...... ",·.-joblc ror '""""' '''''111' .... WI 

"""'- "" .""" ... a. lho <.of"">11 k> """"""'.11, """' ........ "',.,,,, .... ..J 

...J.m.ol,c "'" I<Ol""sibo], .... """'"' "..t1lM< I') tIui .... """ 

lHI [~I'FRSlTy (If< P11 ... ~-fk f""'X'" 1"" ...... " III< -.. """hi<' 1a...J ... 

cl!phI< qaoc> """"""" 1""1 .... I ... ~ _, >Fe< u\,,,,,: 111_ 

dI.rc~~ "",'-lq "tIll .. "....J.....u.........". 'I"''''''' ""' .. , 1Iboo. ......... 1IIJ 

JIDlII'CIS. -.! ._ .. ' ....... I f<II<n'. b."""'1 ...nel • ..! w..... ... I;.!. 

~ tho: llmk>l 'i!.IC .. ".I ~ru.b Im\ IO<!\ok !be :de<l •• ,I( ~ !hoi .... ) 

fIdmRrtoIcIW....:Nr I"JPIIl uoJa _ !l(oJ '" tilt ~ 1MJ'oIlIf 1'fl)!:I", 1II'tJ~ • 

.....-..... hi " • .:wo!lr"b.:r ~ <l ,." ..:~ ..."."" ~b;b. itt 1<nJ<d ((W 

tho 1""'1""" of "'rI<:mmWl~ ~ ro-.ll<lo """'"" j,.".oo""", ..t proJuc .. , ~, .. ..,~~j"d.., k ~ 10.\ ,olhadl$iNo I"'f""'> m,Icr lb!."", ... 

The ~ >bI& dt!<nIIIIWO" ~,........ f«)I.ICio """"" .. LIr<:olhcf 

"""""" 

',CI N/lnm Ttl R~Sll)lJ.rrS M'O tOM.\lUNITY -A'I .~ doaItlln@ • 

1'f\,..:>;aI-..1lI1> ~ !boll 110" f'III''IIIN _10 rao.!.m, 004 .. AA-.! «a1OiIIIIII 

»'Iioler iJ. 1I11l1)~iodon:lIKfllll"fiho"'1!I'-obb<:II«'"I~~-.l<r ~ ", 

"(0) I'IJIIII(' ~t1:ETIl~i \~"" ' tm" >'Ill",,,,,,,,. f'II'f'O>lI >lull t.JlJ I~n~ .. 

tIlCdlIl",~ r=\\._I .... \I'Io.~'·.~ ... Io.'IIICCI_(lO ibt~uf 

<I\tOI~ _ to. ~1041 . ..,.J!he ~l*;~ "" "'""""' .. AD> ~lB!III ~I 

dortl""" M' ~ '. ~ifa.: ~ ~ 91<..,.. f~ """ too -....u..-.! "I'-' olm. 'f!I'III:' "I!fl~1iIOo 

-llIlllI'N1IHCAllON Of ~iAnl:~ TO ACHlLI1J,I!m 01- Co(jlll,S-~.Icl>. 

fII\'J'OSOI <lull HIcaId") otoo..:h II 1110 idIIo: 1>'"""1 If ,""""" f'I\'f!III~ ~h.Jlni 

_UUIOn' ..... 1_-.1 NOt ........ ~ ... I .. -rod< othIo\"""'l<fw~ 1QIit>,.,,,,,,,," ill< i""f'""II ad Ill< P"'f'l'" ui Ill< _ .... . ~_ "Ill< 

oIl<mltJ"~""'fJ .. .'.JIO"'--=Il;~ omoI.<'q'I_o(~"~ 

iii .. ~ ~1IhIIo"" 1"""--rtt"11II .... , ... 0IIh.< m~, '" ""-"""'I ~' odII<I~ .",j, 

p.I .. "J......, u,<~ 

(f) u-.'HlItMATIOtl ~()I( EVM,IIMION-fldl f'I'f')<IJ,taH u..'iIId< 1...,1_ 

~ .. tho lio:fIUn' "' __ .''''''"''1' in alWIllltl\\ft ~Ilb I~ I\JIt~ ('"""'II fur 
39 


-, II~ .. II ............ ,..~ iK\ .. ill< ~ Md_..J fIN:ng N .... 

~ IW1"- ~~ lI>!UIac<. _ ""'" om ... ",~ II>< O(t"'l ~ ....w.". ~1I..a1 

.-....b __ .IWU"'~I" ..... ~ .,..."t.:J\I>"'t-if .... 

"Ill UMIT (1)/ pNi.nml\TluN-I'Ir ...... kI 'iI< 1"""""" b10bcd on pn~"'" IllorW 

I~I, "" s...,,,,,..,. .. ",ted ."""""" oi'i!"""'" \<11.10" .... ." ......... kUI 0IW>a ,l po'ho 

~ ... to ..t ,.....hen:d,:d kllh. ~"'" I>- """' :ado • ..,.."", lnUW """ ...... Iiro~N '" 

"I'IW'_h, lMIIlOl_,b .. ;.))\)", (IIIbho. boMuI~ "",.on!'~ .. lib the~' 

",1«II1II If''''''l'~'' .\mII ............ "'" f'\wk; ~ 1iIoI.rOO) IFJI<l' ~lil1 ..... 11 

o(!IV« """ "',~,; I"'N>< ~'" ., .. '"<I ,,,,,,,,,,-........ I«\<d .. ..,. ...... f"'\I<II'II"" III oM __ ...... ...., ... l!~ orl'llllIooLn' il"·lll "'""' iIt~ ...... d.s _ tb<o 

"" ..... '1"'""\ .r-b!"'''' .... , •• ",.II1II \, ......... idul l OOI_ ... ~wd...,bh'"d ..... 

\41 MAlNTi\INlI'(j l'ARTlClI'ATION AAn:-11. 01\ ....... _ lor ~ ... 

J'OIOOfI'l>OII 11)' .... ~ -.!J .... Irn~ 0lil ron~II" "'' IIIIob ~ m "'" """""" ~ 

ptlb<b.-."""OIIJ'_ba, .... kI~_ tolkbd>ll ..... ..., """'N~ '" 

... ~ 

V"'"~ taell'~" kI..-oflbeio\<IIII ~ ~~'_I<,O'I 

(J~h8~,,,~ (10' ""'"*l WI) f'I"II'I'tl)'~"" orrI'U .... fruo ad ~ lollull'Ml 

""""" lo'oIl<ItIt """"'" Ii' ponK1(IJl< ..... J"roIIIIIB IIQdn- ,II< ~ OQJ ~ lot 

'f'I'I""'" aIol ",'-'<I.,. "'~ • da$ ........... ilia tb. """"'"' 01. J"IbIi< "'-'~ ... ' ft!"..:t...:.,,~~, .... """"""'"''''.,'''"~r-~111,1I\J 

"(Ill" rII$ 11m< .n..-!lot",,"l»I<JI ollUdl r~, \b.: S<I:n:Iof) ... ~ ...:II 

ooJ,h"",," ........ P'1IIJ.u_~.'lhc~d t\lru/l"",...'!(III1Io o.j • ...:e 

<ht1 ..... <!I<S"'fooh"'~I.~ 

til tN 1:U'E!lA! .-~, ron'" W~tf'PI~_ ...... ~0';0IIb~7). OII ..... ~ sbo.II 

.......... I"'~ -.uI rIoa If< I", ...,.. .j f ... ' .. rI Cfom_1ab Ih< IV''Pl' IIIld<r ilul 

...... 1M ...... 1ho ...,.","""""' of ~ IJ.li;BI ad 1M u.cl ...... ~ II kk 

~",,",-.,.j rtpl"'"J u''''' ~ "' '' ~ the pbo, ...... _, ~IUo I .. ",""," 

f'~ N . ... b:oxIioo Ibm}:1 \Jpon !t:k<!'11 otlloo.· 'POl M f"Il~'1lI'I"JII. "" Sca<l.li) 

.. , ml". oallf?'~~1'ldI ".111~ .,i11 u"..,.-tQlJX1Xl)~ t.~ j .... abo 

.".." """ oI!ItiII o&.I!!"",1 ~ .. ,tr> u.""~ ,b _I pa. • ~ ~oh ~ (d) It 

l-liIub~aoJin& "'I <Ott ",,,."" .. of .......... ,. ... faoIlIo ...... ""l$".. .rue, "11,- ........ 

.tfto/I m ... 1ho _nrJo",.(JIOh<tol "'1<" ofopm:> .u..o •• tb.:I' ~(CIlJ odlc:><..eloo>t ~ ~ 

l!it ."....' ~rn: ""'"..,..JI'IIIII! .. tbc(irl'lp" .. 

"(2) tONTI,A{1 AMENmG,:-ti -M.'f ""'''''''1' ~ .....,. ~, .... (\1\ abo 

l>co:r<UIJ WII J'IOIIIM ..... ., 1iJ"PI"*'" -.!,if>lIl\lu(j,:m t/iIIttI ,~...,~ su.h Ip\ " 

"",,"01.1 ,lui lilt .fa>!' ~ f*\ICI\'Ol .. !II,1II ~ ooJ<r 1Iri_"«llOll!l<llllll II< .~' .. " 

,......, ~ •• "'''-(/01) l""t<i<Jorllll,,""," ~1'fI'I\'IIdp<don.lcrihl> 

~ .. (C\<q'O flO I'<ULIl<I;I r .. ''' .... -.kt ~ IJK~!1 ~ •• .-..I !'Ioo .... """""''''' .d~J~ ., ..... iJ'<.i'~\."'''''~ ~"":'" II"" _not! ............ Ad 'F""" .... '~It. 

f"'l~""""" ....... u,,,>11\1",,, II! "'., ..... "" .. """,>I\Ibk: 1OlI0«" iii< l>«nWf 

'"(1) PROGltAM t'UNl).~-A ~.,! .'"e> i!II! ....... _ .... , ..... "><11.-.1,, !/It "1:""" fn"Q abo OJ-i"'J fond .... -0:..1 .... 91.\ _, "",..lo.l III""""", rn..1hr 

l'o(I.IW f'-.lla)n ........ \lid\ III.l ........ , ]'O\l'idoJ 0> tIoc of<IICv ~ 'I ..... """11>1( IIntWln~ ..... AAI"~f ... ) 0I>kr -<'<!lOIlj1ol-.J aIO) kilOe ~.-Io f'.'fnIlI ~ fl)l' MI' otto""" 

lb_ .. """'Will k >;t«lOIl1i,Oj IV 9 ~ 0iIv;J """"" fr. h'U<)! ,." '" [01' ~' !'IIoa 

E\J,'It>O<""'-ott-...:K"''''''''<* .... lh .. <a:IIoIL .. ,I.:.a...-l to ""'~ 
40 


'I~lltll~ 't'RN..-I. ",",,'1111!'" rt< 1"'l'!CT""1IDJcrtht<""""",.a4 pm",~", 

..,...) ~..- .. -.. tho1llllllcrl'bfliKiMI'_ r..lli,qooI., .. _ol 

r.-J\ ~m._""'<'f'I .. )'<tII:>Ikd...Jn <Ubron)'l1l[ohlOI 

-ti) .... ..,...:) "'"), 0\ I ........ R>.Ioc< ~ • ....MoI' .... >Ia1( .... ,.., II ",,1. 

!"I ~"l ~ul •• _cd r"""~t.stl .... bc!llll\ ,f'i""""wfill>llsr<>l.lll."'r f~ ...,~ ............ ",.H~~"'lhsl«_, 

I)) n\l<l« UI<._m ,,_>1<11 ..... "'" II <CI\'c> b\ If~' to~ ... 

tho ~ ......... ('/ III "<'II(M bo;ell/lotillcJlogl, I~ i!I< ., ... II\Jcr 

,_(,,~ n.<Mlh ,I~."""" _IIW: l,..J,;mIliI.Jo, fn ... """, I 

"'"..,..'"ro.l\.""""cl.._""'III<II<WI)....,..,,"'""""'~_""'-,. 

"'"""bl.""'i""'~,., ,"'f"' ~~.--..,oN 

11J)1'I'O.Ioot: IDt lIDIbc! of ~ r.,.ili<3" ~\'" t'j "'~, I~ ~ .. ~ 

1bI~<yllI ....... oI,"'''odo<rllow:blo«0Icl<>01<oIoh<'~'*'''' 

cl.no Ill..! okI_ (Ii ,ila... cl-=~ till! Old! Il'oh< .... ~ "'"" me lOb!, 

n"uJ",,~ m." "",b oJJ~ . .. ~ ru.!octit .. '" """' ..... ","",' ,.,m _",,\I 

I ... "" 

lq N'I'ROVAI, Of Rt1lli!:TIVh";-1bo ~",', lel'd " t(I"" oIIi "I1'l"'~ 1 

Qi ... ,...\. roJI<'!~' """'" ill< ~ 011_,""",.",1>1 I<do-<. l$""....J Ito"' ,,~ '--Imt .mil .., __ ,til ill< k-I.! of 1bo rm"",,", f""'t'.,..J .,.j do: p'1«IIII01 

mq .. III ~ 1...,1><I.,.j , .. Ihr ~ ~ ~ $(-.:1, (,~ o:!o!IAAI f .. ,I", 1,,"chl1",, 

~«IIIu_,Tbcii<.:ldll)....u.---

i'l Illl<otit ,01 rN...:I_.x..,...,.~ 18~1I"'1\' """>\~ ... ~ 

...u...:. at 1110 _ aI ,...,. I"\~ 1:1\ lbo '~', ... the!' lit 

~ ... ~ ~'W1do!""""'nlt<Wrlhoi'l"!'>SCJ...,,"! I' 

_oil alol "'" d1"<lJ\~', IIIJ 

(IiI III \110..,., ill n:.ho:tIoti _ ~ (ijo:ll~ U). tr\"I'I1l'i 

<00:) R>J\o:, .... In Ill< _ I/IJ Jin'lll fII'I'l""J )Iy IlIo oguI<l III\<S> tho> 

.. ,....."' .. ~'~"'_J"k'Icth<-<Of"lI;)o;j"YI ~ 

rro"'l.>la.. ........ ~.<ILII1 ~l""f"'<Il.Iol~' .. ,f"''1'''I.I>r· 

'"'~ .... bo~IIIoI~"'.I'I~\IOol~III'lcr .. t>..I_(l~lIfhi\,oh< 

SocreI.u} <ball ~ o/Nn,.w. 10>' \l><.,.:\ ., ......,. C\"""""",",o:f{..Jiat ... 

ob:r """'""" hl~ Ib< ""'PI'" r""",., '" IU<'Il i\'O' II< i"'-f'1'<'l ""'1'I<'S 

..J tbo 1I>tL ... rI • Ip<\ ~, 1<I""I<'.<IIdI .. """toot>:m ~ • ",,,,,,,,,,I 

"''"''', ..... ~ iii< I£"IC' dLJ '"" ",1I!. • .u~ cfI<II1~'" , ..... rto: ... .....,;0 

"",,-.do:d, ~,.,- 110.01 iii< ~ Ult ... "",",'" III .,....." ... ""1ft """ """"""""'"" ... w''''''(,~_..,.l''''''lIIN ........... 

,Ill oI.l_IERNAI~ MI'.AMl!£ fOR Rl'llUt' ntlNS_WII/t ~ '" i"""'aoj 

.. -dtEl_ onJcr ~""' rll~iil!hc """"'''''"'') lISt iII<"'<ddd """,a... 01 .. 

"F"'I'\ .• poillio """""" iN<d ... '" (Nt« dtb< .... """1.1 <qIOloieru III III , ,...., • "OII<beo 

bud ... rIO O@<I'<""'WI bal~ ~go,r __ ~ ...... poibI~ !.>un;; ""'" lboo \llo>:h.n 
41 


-, 1E, (:OO!NI!A TIOII 01' i'UMllTrJ) Rb1>OCTI0NS ..... AI .... on<! (If u,. rcnuJ 

~<>l t, w,:I<= .... fit • f"I'OIIIlN!M><b.ol UD.l<1 ~~ (CIOJ (Of 0lI 'P! 

Ih< "fOIII'\ _U ...... , • r.,.,1 rq'«I (JO II:!< """"" Q( Ill< 1IIIl.all,e fuoJ.>J .1111 ""b 

~"'"' adt>lOI~ ,,,,mrr.<.,.J " .... .IIIJ "lb<r ~ ~ ~ b<"," s..:""", til _,..., ~,tl! u." MI'''''''' l'_'1l ilIIda _ ... tJ~l~ ~b>:11 "'*! 

..:IuJo . r'lll'l<>i ............ _ lOll! ..r_ "'""""""'~ """"" I'n"..!al hi tilt 

opI<' II'lho: .... ""'~ ..... IO_IIW<"k ..... ~,..;,.~"' ."""',.,>t •• oI • 

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52 

PREPARED STATEMENT OF DIANNE HOVDESTAD 

DEPUTY DIRECTOR, SIOUX FALLS HOUSING AND REDEVELOPMENT COMMISSION, ON

BEHALF OF THE NATIONAL ASSOCIATION OF HOUSING AND REDEVELOPMENT OFFICIALS

AUGUST 1, 2012 

Chairman Menendez, Ranking Member DeMint, Members of the Subcommittee on 

Housing, Transportation, and Community Development, thank you for giving me the 

opportunity to provide information and perspective on ‘‘Streamlining and Strengthening HUD’s Rental Assistance Programs’’. My name is Dianne Hovdestad; I currently serve as the Deputy Director of the Sioux Falls Housing and Redevelopment 

Commission (SFHRC) in Sioux Falls, South Dakota. SFHRC provides rental assistance to approximately 2,000 households by utilizing various HUD-funded programs. 

These include: the Section 8 Housing Choice Voucher (HCV) program; the Section 

8 Moderate Rehabilitation Program, public housing, programs funded through the 

McKinney-Vento Act, including Shelter Plus Care and Housing Opportunities for 

Persons with AIDS; HOME Tenant-Based Rental Assistance; and the Section 8 

Multi-Family program. In addition, the SFHRC provides affordable housing using 

Neighborhood Stabilization Program funding and is currently working toward the 

construction of additional affordable housing using the Low-Income Housing Tax 

Credit program and the HOME program. 

I am also proudly representing the National Association of Housing and Redevelopment Officials (NAHRO), one of the Nation’s oldest and largest housing advocacy 

organizations. NAHRO currently represents over 22,000 individual members and 

over 3,200 housing and redevelopment authorities across the country. NAHRO has 

led the fight for cost-effective legislative reform of the Section 8 voucher program 

over the past 10 years. Speaking for myself as someone who has been involved in 

the housing industry as a professional for 35 years, I am particularly pleased to 

have the opportunity to address the Subcommittee today on the critically important 

matter of streamlining and strengthening HUD’s Rental Assistance Programs, particularly the Section 8 voucher program. 

Responsible Program Administration During a Period of Fiscal Restraint 

I think it is safe to say that this hearing is being held at a time when economic 

and political considerations affecting the Nation’s fiscal health are in more dramatic 

focus than they were when we began the conversation about administrative and programmatic reform of the Section 8 voucher program—nearly 10 years ago. Speaking 

not only for housing authorities in South Dakota but on behalf of my colleagues 

across the country, I think the need to support responsible reform of the Section 8 

voucher program is more pressing and more important today than it was in 2002. 

In my own case, the work of my authority and our own efforts to support those in 

need of decent, safe, sanitary and affordable housing in Sioux Falls have been greatly impacted by spending reductions, which have drastically reduced available funding to operationalize the voucher program. In particular, Section 8 administrative 

fees have been reduced to such an extent that in testimony before the Senate’s own 

THUD Appropriations Subcommittee, HUD Secretary Donovan testified that housing authorities in growing numbers were telling HUD that they would no longer be 

able to afford to run the voucher program—including the highly praised Veterans 

Affairs Supportive Housing (VASH) program that serves America’s veterans. Since 

that admission earlier this year, the numbers of housing authorities in the same position has only grown. This alone should compel this Subcommittee to act now to 

reform this critically important program by reducing administrative burdens that 

not only cost the Federal Government money in a time of fiscal restraint but also 

impair housing authorities’ abilities to serve families, seniors and the disabled who 

rely on this program to ensure a decent, safe and affordable place to call home. 

The Section 8 HCV program is a regulation-rich program. The myriad of complex 

regulations make the program difficult to administer and difficult for recipients and 

landlords alike to participate in. Program operations are subject to administrative 

directives, rules and regulations of Federal and State agencies including, but not 

limited to, HUD. Administrative directives, rules and regulations are always subject 

to change. Most often such changes may occur with little notice, and/or inadequate 

funding to pay for related costs. These same changes usually increase administrative burdens that simply add cost, often with a limited net gain in efficiency. I want 

to thank you for holding this hearing and for your commitment to addressing the 

pressing need for reform properly through the authorization process. Hopefully your 

work and your leadership will result in thoughtful and purposeful improvements in 

HUD’s rental assistance programs—most particularly the voucher program. 

53 

Necessary Funding to Properly Administer the Voucher Program 

The work of SFHRC, as well as that of other housing authorities across South Dakota and the Nation, has been greatly impacted by significant cuts in administrative 

fees over the past 10 years. By way of example, in 2003, SFHRC received $970,000 

to cover the costs of administering $7,300,000 in housing assistance payments under 

the voucher program. In addition, SFHRC was paid by HUD for audit reimbursement costs, hard-to-house fees, assessment and preliminary fees for tenant-protection vouchers. Each year since, SFHRC has received less administrative fee dollars 

than it has earned, due to shortfalls in appropriations which led to significant administrative fee pro-rations. SFHRC was able to meet the program’s regulatory requirements through the utilization of its Section 8 administrative fee reserves, currently referred to as Unrestricted Net Assets (UNA). Unfortunately, SFHRC has 

now spent down most of its UNA, so it no longer has that resource to cover future 

program expenses. Sound business practice is to have the equivalent of six months 

of operational expenses in reserves. SFHRC’s current UNA would cover approximately 12 days of operational expenses. SFHRC anticipates it will receive administrative fees of $950,000 for calendar year 2012 to administer approximately $10,000,000 in rental assistance dollars. Due 

to the pro-ration I referred to earlier, SFHRC will receive a mere $0.80 for every 

$1.00 it earns. The consequences of the decrease in administrative fees have been 

a decrease in customer service to both the recipients and the landlords. Sadly, as 

I understand from discussions with my NAHRO colleagues, this is now the norm. 

SFHRC has not been able to replace staff who have left its employ; remaining staff 

have to labor under an increased daily workload. As a consequence, SFHRC does 

not have the funds to pay for overtime, as required by Federal labor laws, so households are waiting longer for inspections. Recipients, landlords, applicants and the 

community wait longer for answers to questions. Landlords in particular are becoming so upset with this delayed response that they are threatening to leave the program. 

Decreases in administrative fees have also led to a problem with utilization of 

SFHRC’s annual budget authority for the voucher program. In calendar years 2008– 

2011 for example, SFHRC utilized 100 percent of its vouchers. In calendar year 

2012, SFHRC utilization rates are approximately 95.67 percent, even though 

SFHRC has over 3,500 households who are on its waiting list. Our wait time is approximately 4 years. The 4.33 percent that is available but not utilized represents 

92 very low-income households who are also in desperate need but who are not receiving assistance with their rent each month. Simply put, fewer staff means fewer 

people can be served. 

The bottom line? NAHRO projects that 87,352 fewer households will receive 

much-needed rental assistance due to staff reductions from lack of administrative 

fees. This figure excludes all incremental and special voucher programs. NAHRO is 

happy to make available to the Subcommittee their most recent administrative fee 

survey, as well as a chart showing the historic relationship between administrative 

fee pro-rations at pre-Quality Housing Work Responsibility Act (QHWRA) rate and 

housing authorities’ ability to lease and serve low-income households. 

Reform Provisions Central to Any Bill To Be Adopted 

I believe that today’s hearing is a very positive step forward in the effort to bring 

about desperately needed changes that will make the voucher program more inviting to landlords, better able to ease current administrative burdens on staff and better able to assist the very low- and extremely low-income households in need of affordable housing. At NAHRO we believe that local discretion is the key to providing 

flexibility for program administrators that serve these households in varied geographic and economic conditions. 

For several years now there has been much talk in Washington about proposed 

reforms that would make the administration of the voucher program and the delivery of other rental assistance programs more effective and efficient—including, for 

example, statutory changes to improve the Family Self-Sufficiency (FSS) program. 

Here again, an adequate, consistent subsidy structure is key to a successful program. A program like FSS needs stable funding, as it is difficult to manage due to 

the uncertainty of annual appropriations for housing assistance payments and administrative fees. Again, it takes people to serve people, but it also takes adequate 

and properly deployed funding to help move families out of poverty and on to a life 

based upon individual achievement, accomplishment, and fulfillment. 

Mr. Chairman we believe that there are several factors or components that are 

essential to any reform bill you ultimately adopt. At this time, I would like to highlight those factors, recognizing that several of these components have been part of 

previous reform bills that have been under consideration here in Washington. 

54 

Housing Quality Standards and Property Inspection Protocols 

Under current regulations, a housing authority cannot provide rental assistance 

until it has determined that a dwelling unit that a voucher holder wishes to rent 

meets HUD’s Housing Quality Standards (HQS). This regulation applies whether 

the unit is brand new or 100 years old. NAHRO and my colleagues in South Dakota 

support the enactment of legislative changes that would give agencies discretionary 

authority to start paying rental assistance from the date of the initial property or 

unit inspection if there are only minor HQS violations, i.e., conditional approval, 

where in addition the rent is reasonable. We believe that adequate safeguards are 

in place to ensure that housing assistance payments will be withheld and assistance 

abated in 30 days, from the date of the initial inspection, if the violations are not 

corrected. This simple, straightforward change would benefit both recipients and 

landlords. Recipients would receive quicker rental assistance in a safe and healthy 

environment and landlords would have an incentive to participate in the program 

since they would not lose income while correcting minor violations. A majority of 

landlords participating in the voucher programs administered across South Dakota 

are in fact small business owners. Any assistance that can be provided to them in 

the operation of their rental property with limited loss of income is a win for everyone. On this point, I would like to note that HUD program regulations allowed ‘‘conditional approval’’ of units from the inception of the Section 8 Certificate program 

until 1980. SFHRC has exercised this option and it has worked very well for the 

reasons I noted above. 

In an effort to ease unnecessary regulatory burdens, NAHRO also continues to 

support the discretionary authority to inspect voucher program units every 2 years, 

while acknowledging that this may not be the right solution for all housing authorities. This would allow housing authorities to perform inspections on a geographic 

basis instead of tying inspections to each household’s lease anniversary date. It is 

important to note that in South Dakota, as well as other rural areas across the 

country, there are housing authorities that administer the voucher program across 

significantly large geographical areas. For most of those housing authorities, it 

would not be uncommon for staff to drive 100 miles or more to conduct an inspection. The annual inspection process is a major program expense when considering 

staff salaries (including driving time to the inspection and the necessary time to 

conduct the on-site property inspections), gas costs, vehicle maintenance, and reimbursement for meals while traveling to and from the property We believe that local 

discretion to inspect units on a biennial basis is a critically important cost-savings 

measure that should be included in any reform bill you consider. 

Finally on this point, in areas of the country where Low-income Housing Tax 

Credit, HOME or other multifamily properties are inspected by other governmental 

agencies such as a State housing finance authority, we believe that housing authorities should have the discretion to use inspections conducted by those entities, as 

long as the inspection criteria meets or exceeds HQS, in lieu of conducting our own 

HQS inspection. 

Income and Rent Determinations 

A second component central to any reform effort deals with the evaluation of resident income and the determination of tenant rents. The complexity of the rent and 

income calculations existing under current regulation is daunting, and no doubt 

underlies many of the problems experienced under current rules with respect to 

payment error. NAHRO recognizes that efforts to address rent simplicity, and more 

particularly ‘‘rent reform,’’ are inherently controversial. Nevertheless, any effort to 

simplify the rent and income calculation process should be pursued with all deliberate speed. 

All of the various bills which have been in circulation and under review for years, 

including the Section Eight Voucher Reform Act (SEVRA), the Section Eight Savings Act (SESA) and now the Affordable Housing Self-Sufficiency and Improvement 

Act (AHSSIA) which is currently under consideration by the House Financial Services Committee, include titles intended to provide ‘‘income and rent simplicity.’’ 

However, with all the changes over the years in each of the bills, housing authorities that have examined this issue indicate that none of them accomplish the intended goal of determining household income and calculating households’ rent 

shares simply, as in the definition above. I would like to highlight some of our concerns and recommendations regarding income and rent provisions. 

First and foremost, an operational definition of ‘‘income and rent simplicity’’ is an 

income definition and household rent calculation method that is relatively simple for 

housing authorities to calculate and administer, leaves the Brooke Amendment in 

place for existing assisted households by household type (not each individual household) within each housing authority, but does not automatically create a set of inVerDate Nov 24 2008 09:17 Apr 26, 2013 Jkt 048080 PO 00000 Frm 00058 Fmt 6621 Sfmt 6621 L:\HEARINGS 2012\08-01 & 12-11 HUD S RENTAL HOUSING ASSISTANCE PROGRAMS, 
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tended incentives or disincentives for low-income households, and provides a greater 

degree of transparency to participating households property owners and managers. 

By contrast, an operational definition of ‘‘income and rent reform’’ is an income definition and household rent calculation method that is relatively simple for housing 

authorities to administer, does not necessarily leave the Brooke Amendment in 

place for existing or future assisted households by household type (not each individual household) within each individual housing authority, likely creates a set of 

intended incentives or disincentives for low-income households, and likely provides 

a greater degree of transparency to participating households property owners and 

managers. 

With this in mind, NAHRO is particularly concerned about two areas of potential 

hardship related to elderly and disabled families and families with dependent children. In any legislation you adopt, we urge you to include a provision that authorizes the Secretary, by regulation and for a period not exceeding 3 years following 

the date of enactment, to limit increases in rent for elderly or disabled families and 

for families with dependent children whose rent has increased due to changes in the 

allowable exclusions for medical expenses or child care expenses. 

It is also important to point out that the rent and income provisions you consider 

and possibly adopt may have an unintended and negative impact on housing authorities’ rent revenue in the public housing program. For example, the New York 

City Housing Authority has estimated that its public housing rent revenue from 

residents would decrease substantially as a result of legislative changes affecting 

rent and income. Thus, we urge you to include in any bill you adopt a provision that 

would authorize compensation to housing authorities through increased Operating 

Funds. 

Housing authorities are required to verify and report to HUD all sources and 

amounts of included and excluded household income. While securing third-party 

verification of income that is to be included in determining annual income and rent 

does make sense, the noteworthy expense of verifying excluded income to be reported to HUD does not. Additionally, verification of allowable deductions is another 

time-consuming and costly administrative process. 

If income and rent determinations are done in a way that meets the principal and 

intended goals and objectives of the voucher program, and if income and rent determinations could be conducted in a way that would otherwise benefit low-income 

households, then I believe that property owners and the remaining 99 percent of 

public housing authorities that are not MTW agencies would benefit in terms of reduced administrative burdens. The Federal Government would also directly benefit 

from administrative cost savings. I am certain Mr. Kinard of the Newark Housing 

Authority can provide you with comments from the vantage point of an MTW agency. 

As the representative of a non-MTW agency in South Dakota, I think that any 

changes in income and rent simplicity provisions in the voucher, public housing and 

project-based rental assistance program should reduce burdensome reporting requirements placed on recipients and should relieve housing authority staff of many 

verification and processing tasks that only add cost. As a professional and as a taxpayer I also believe that a proper income and rent methodology should reduce the 

amount of improper payments. 

I encourage you to add language to any reform legislation you adopt that would 

authorize recertifications for fixed-income households every 3 years, with the application of an annual adjustment factor to their income. This would provide relief to 

recipients who struggle to attend appointments due to physical limitations or lack 

of reliable transportation. I also encourage and support other simplification provisions, such as eliminating the requirement to verify and maintain records of excluded income, as well as the requirement to use a household’s prior year’s income. 

I also support the ability to use income determinations made by other Government 

agencies. 

In addition to reducing the reporting and processing responsibility on low-income 

households and housing authority staff, income and rent reform changes have the 

potential of promoting employment among assisted households without the immediate burden of paying a higher rent. Modest reduction of the interim reporting requirement for decreases and increases in households’ earned income, for example, 

along with exclusion of the first 10 percent of earned income up to $9,000, should 

provide greater incentive for some working households to remain gainfully employed. 

Households with children in particular should also get the benefit of an increase 

in the dependent allowance and any program reform bill you adopt should permit 

an adjustment in the threshold for unreimbursed child care expenses from 10 percent to 5 percent of gross income. Current regulations allow a dollar-for-dollar deVerDate Nov 24 2008 09:17 Apr 26, 2013 Jkt 048080 PO 00000 Frm 00059 Fmt 6621 Sfmt 6621 L:\HEARINGS 2012\08-01 & 12-11 HUD S RENTAL HOUSING ASSISTANCE PROGRAMS, 
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duction in gross income for unreimbursed child care. This new adjustment to child 

care deduction would increase the household’s rent. 

Finally, NAHRO supports language that would enable a housing authority to implement alternative tenant rent structures in rental assistance that preserves the 

Brooke Amendment. Alternative rent methods include the continuation of flat rents 

based on the rental value of the unit, income-tiered rents, rents based on a percentage of the household’s income and the use of existing rent structures. NAHRO believes that alternative approaches to income and rent determinations, when carefully reviewed and analyzed for their likely effects, offer important lessons for possible further improvements for all assisted agencies and owners and provide opportunities for outcome-based research for a menu of locally based options in the future. 

Funding Policy 

As I mentioned earlier, the uncertainty of the renewal funding process in recent 

years has made the management and operation of the voucher program a difficult 

challenge. The goal of any housing authority is to maximize its leasing up to its 

baseline total of authorized vouchers in order to assist as many families as possible. 

Unfortunately, with constant formula changes over the years and delays in the annual budget process, many agencies have been hesitant to issue vouchers—either to 

keep from over-committing their dollars, or to keep from leasing beyond their baseline until they know their annual appropriation. 

A provision found in the December 1, 2010, version of SEVRA that bases funding 

on the actual leasing and voucher costs for the prior calendar year and the 5-year 

authorization for renewing leased vouchers for example provides much-needed stability to properly manage the program. Authorization to retain 6 percent of annual 

budget authority in Net Restricted Assets (NRA) is also an important provision in 

any final legislation you adopt. 

As I stated earlier, reductions in administrative fee funds have already had an 

impact on the number of families that housing authorities can serve on a national 

basis. NAHRO is very concerned that additional funding reductions in FY2013 could 

lead to more perilous consequences across the country if a remedy cannot be agreed 

to and implemented in a timely fashion. NAHRO has two proposals, either one of 

which can responsibly mitigate decreased administrative fee funding. The first 

would allow the current HAP and administrative fee accounts to be combined into 

one account, providing local authorities with the discretion to utilize those dollars 

with proper safeguards built in. A second approach would allow housing authorities 

to utilize unused NRA to supplement dwindling administrative fee dollars—again, 

with proper safeguards built in. NAHRO would welcome the opportunity to discuss 

these recommendations with you in greater detail as you continue to deliberate the 

content of voucher reform legislation. 

NAHRO has also prepared a detailed analysis that addresses voucher funding 

practices over the years, and has recommendations that will address problems related to an uneven and unstable funding policy. 

Utility Allowances 

Currently, each housing authority must devise a utility schedule for their jurisdiction. The data is often imprecise and continually changing. For an agency with a 

large geographic area, or with multiple providers of a certain utility, the task is arduous, time-consuming, and costly. Consider, too, all the small public service districts. NAHRO recommends that HUD be required to share utility costs with housing authorities and allow them, if they so desire, to utilize these estimated utility 

costs as standard allowances. I sincerely hope that this language is included in any 

bill that you ultimately adopt. 

If HUD were required to publish utility information each year by State and region 

from other governmental sources, housing authorities would know whether or not 

utility rates in their respective areas increased by 10 percent or more in order to 

determine whether or not conducting extensive calculations of utility rates and consumption were warranted. We certainly hope the Subcommittee will address this apparent inconsistency. Housing authorities should be able to use the utility allowance 

of a household’s authorized voucher size if the bedroom size of their leased unit is 

greater than their authorized voucher size. During the drafting of AHSSIA, your colleagues in the House responsibly included language proposed by NAHRO that does 

exactly that. 

Finally, housing authorities should be allowed to use the lower of their utility 

companies’ ‘‘lifeline’’ rates or the standard commercial rate averages where applicable and be able to average annual utility allowances by bedroom size in lieu of utility allowances by structure type. Alternatively, housing authorities should be able 

57 

to survey their area utility charges and consumption rates, document them, and propose average utility allowances by bedroom size, subject to HUD approval. This 

would significantly reduce the complexity and calculation errors by housing authorities for utility allowances, and greatly simplify the leasing process for voucher holders and property owners to help create less programmatic barriers to low-income assisted households accessing the housing market relative to unassisted households. 

Current Legislative Reform Proposals Before the Congress 

With one notable exception, much of the December 1, 2010, version of SEVRA 

(Section 8 Voucher Reform Act) provides a thoughtful and pragmatic platform to 

begin your current review and analysis and hopefully represents a workable place 

to begin your work on voucher reform. In 2010, this version of SEVRA was actively 

discussed for possible inclusion in the 2011 appropriation bill under consideration 

at that time. As such, it was a vehicle that a number of our industry colleagues, 

if pressed, likely could have supported. NAHRO played an active role in moving this 

particular version of events forward and formally endorsed this particular legislative 

draft. 

As I mentioned earlier in my statement, the time for action is now. The 111th 

Congress had an opportunity to advance a bill that NAHRO felt made good sense, 

practically and politically. The December 1, 2010, version of SEVRA was a rather 

scaled-down version of earlier iterations of SEVRA legislation from years past but 

it was, never the less, a meaningful and practical bill. That bill did not contain everything we had hoped for, but it did contain much that we could support, including 

the following: 

Income Targeting: The December 1, 2010, version of SEVRA improved income targeting for all extremely low-income applicant households, with particular benefits 

for families in rural communities and large-size families in metropolitan communities, by using the higher of the Federal poverty level or extremely low-income 

thresholds. It provided better access to the Section 8 HCV program, public housing 

program, and project-based Section 8 multifamily housing assistance programs. 

Housing Quality Standards and Inspection Process: The December 1, 2010, 

version of SEVRA also included a number of inspection-related provisions, including 

ones that would: allow housing authorities the discretionary authority to conduct 

HQS inspections of all of their voucher-assisted units every 2-years rather than annually; permit housing authorities to perform inspections on a geographical basis; 

allow inspections conducted by other entities to be used in place of a housing authority-conducted HQS inspection; and permit a housing authority at its discretion 

to allow a voucher-assisted household to move into a dwelling unit after signing a 

lease with a property owner for a unit that has a reasonable rent and no health 

or safety violations, such that an agency may commence a lease, execute a HAP contract and verify within 30 days that the unit passes HQS. 

Administrative Simplicity for Income and Rent Reviews: Administrative simplification provisions in the December 1, 2010, version of SEVRA also track with the reforms noted in my testimony today. That version of SEVRA would have relieved 

housing authorities of the responsibility to maintain records of miscellaneous HUDrequired income exclusions, and would have allowed housing authorities to use applicable inflation adjustments for fixed-income families. Additionally, language in 

that bill permitted housing authorities safe harbor reliance on other governmental 

income determinations (e.g., Medicaid, TANF), and allowed housing authorities to 

make other appropriate adjustments when using prior year’s calculations of other 

types of income. These would be welcome additions to the HCV program. NAHRO 

also supported provisions regarding housing authorities’ use of households’ prioryear earned income and alternative rent structures that would be allowed under the 

voucher, public housing and project-based Section 8 programs. 

Expansion of Family Self-Sufficiency Program (FSS): The December 1, 2010, 

version of SEVRA converted the Family Self-Sufficiency (FSS) program from an annual competitive grant to an administrative fee to pay for the cost of an FSS coordinator as part of the standard administrative fee provided to housing authorities. Additionally, language in the bill would have established standards for the number of 

FSS coordinators that an agency may fund and restored coordinator funding for 

agencies with effective FSS programs that lost funding in prior years for reasons 

unrelated to performance. 

Payment Standards, Fair Market Rents, and Utility Allowances: The December 1, 

2010, version of SEVRA required HUD to approve housing authority requests to 

raise the payment standard to up to 120 percent of the Fair Market Rent (FMR) 

for housing authorities with high rent burdens or high concentrations of poverty. To 

provide reasonable accommodations for persons with disabilities, the proposed bill 

also permitted housing authorities to, without HUD approval, increase payment 

58 

standards up to 120 percent of the FMR. Also, HUD was authorized to approve payment standard requests in excess of 120 percent of FMR. The 2010 bill also improved the timing of HUD-published FMR values. This version of SEVRA also required HUD to publish data regarding utility consumption and costs in local areas 

as is useful for the establishment of allowances for tenant-based utilities for voucher 

families. 

Access to HUD Programs for Persons With Limited English Proficiency: The 2010 

bill language also included a requirement that HUD develop and make available 

translations of vital documents developed by a HUD-convened task force, establish 

a toll-free number and document clearing house, and complete a study of best practices for improving language services for individuals with Limited English Proficiency (LEP). 

Project-Based Voucher Assistance Program: Finally, the December 1, 2010, version 

of SEVRA would have amended the percentage of units that can have project-based 

assistance in an agency’s voucher portfolio; provided protections against displacement for families who reside in a dwelling unit proposed to be assisted under the 

PBV program; and permitted the use of site-based waiting lists under the PBV program—all of which NAHRO supported. 

AHSSIA 

In the period of time between December of 2010 and today, your House colleagues 

on the Financial Services Committee have advanced two separate reform proposals: 

the Section 8 Savings Act (SESA) and the current Affordable Housing Self Sufficiency Improvement Act of 2012 (AHSSIA). At present, an AHSSIA draft proposal 

has already been approved by the Insurance, Housing and Community Opportunity 

Subcommittee. We understand that the draft is currently being readied for a full 

Committee mark-up, which will hopefully take place following the August recess. 

We at NAHRO believe that there is much that we can support in the most recent 

AHSSIA draft. I would add the fact that NAHRO’s many discussions with House 

staff about improving that proposal even further have been fruitful and productive. 

Our views on the most recent draft of AHSSIA are as follows: 

Funding Voucher Renewals: With respect to Housing Assistance Payments and 

Net Restricted HAP Assets, NAHRO believes that regulatory and administrative reforms are desperately needed. The backbone upon which the voucher program relies 

to achieve its historic success—a sound funding policy—has been thrown off kilter 

over the years and is in need of improvement. Housing authorities around the country have witnessed a widening gap between budget utilization rates and their 

voucher lease-up rates (percentage of authorized vouchers leased). As a result, many 

housing authorities are now serving fewer families than their authorized number of 

vouchers. We would submit that prudent, strategic and purposeful application of a 

sound funding policies based on lessons learned, and the restoration of the renewal 

HAP funding policy that was in place in FY2003 represent the centerpiece of any 

voucher reform legislation and accordingly should be included in the final bill you 

adopt. Please know that funding policies recommended by NAHRO over many years 

do not increase the amount of required funding, but rather distribute this limited 

Federal resource on a sound and rational basis subject to pro-rations. This approach 

we believe would provide a greater measure of transparency and accountability to 

voucher programs. We are pleased to see that the most recent draft of AHSSIA does 

contain a voucher renewal policy that for the most part includes these important 

components. But we are concerned however that offsets of MTW agency dollars are 

anticipated in the most recent House draft with respect to voucher renewals. We 

oppose offsets of this nature and we are working with House staff to find a mutually 

acceptable solution. To avoid problems such as this, we suggest that this Subcommittee formally adopt language on this subject that has been a part of THUD 

bills for the past 7 years. This language would avoid overfunding/underfunding of 

housing authority dollars and the formula for renewals in these same bills is based 

upon actual cost data from housing authorities. Both components are necessary and 

entirely appropriate and we urge that you include language in your bill that anticipates and includes language to support these important points. 

Financial Self Sufficiency (FSS): NAHRO has supported the inclusion of language 

concerning the FSS program in AHSSIA and has been pleased to support the provision championed by Chairwoman Biggert over several years. We would, however, 

note that HUD has also advanced FSS reform legislation that also appears to 

achieve many of the objectives NAHRO could support. Senator Reed, a distinguished 

Member of the Banking Committee, is also very involved in the FSS discussion. Our 

hope is that a consensus product will be hammered out and will part of any final 

reform bill that Congress approves going forward. We feel confident we could supVerDate Nov 24 2008 09:17 Apr 26, 2013 Jkt 048080 PO 00000 Frm 00062 Fmt 6621 Sfmt 6621 L:\HEARINGS 2012\08-01 & 12-11 HUD S RENTAL HOUSING ASSISTANCE PROGRAMS, 
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port a responsive FSS provision in any final reform product you adopt based upon 

our most recent review of proposals currently on the table. 

In all circumstances however, current experience over the last several years have 

shown us that unless Congressional appropriators increase funding for the expanded 

FSS program contemplated by HUD, Senator Reed and Representative Biggert, existing agencies with successful FSS programs will lose much-needed funding. 

NAHRO recommends coordination between this Subcommittee and the THUD Appropriations Subcommittee as this legislation moves forward to ensure that there 

are not unintended consequences of existing agencies inadvertently losing their existing FSS funding. 

Restoration of ‘‘Maximized Leasing’’ and an Explicit Policy on Net Restricted Assets: Earlier AHSSIA discussion drafts have included language that states 

‘‘[r]eserves may be used for overleasing in any year, regardless of whether such use 

is eligible for renewal funding in a subsequent calendar year.’’ Although the language contained in earlier AHSSIA discussion drafts does not state whether the use 

of reserves would be eligible for HAP renewal funding, NAHRO is at a minimum 

pleased these provisions would reinstate ‘‘maximized leasing’’—a wise and prudent 

practice that worked effectively prior to FY2003. Maximized leasing was an option 

formerly available to housing authorities for many years under the voucher program. It has enabled them to serve the maximum number of households possible 

with the annual amounts provided to them, so long as their annual spending over 

the subsequent year did not exceed 100 percent of their contracted units over the 

2-year period. 

Ongoing Administrative Fees: NAHRO believes that studying administrative fees 

in the voucher program is necessary. We believe that a study, if well-designed and 

well-executed, can illustrate the voucher program’s current condition relative to 

these goals, and would illustrate examples where a balance is being struck between 

the methods housing authorities are using to achieve balanced outcomes within 

their budgets. However, we feel strongly that final determinations regarding administrative fee rates should not be left open to change by the Executive Branch. If allowed by Congress, one Administration could, for example, use the authority to significantly incentivize use of vouchers in metropolitan and suburban areas at the expense of rural communities unmet affordable housing needs; another Administration 

could use its authority to significantly incentivize widespread use of deep rental 

housing subsidies at the highest end of agencies’ payment standard authority even 

if it meant serving fewer families overall. Still another Administration could use its 

authority to significantly incentivize home ownership at the expense of rental housing opportunity. 

Administrative fee rates have been established in statute over the history of the 

HCV program with operational success, without undue influence by any Administration. The Office of Management and Budget (OMB) has consistently given the HCV 

program the highest rating awarded to any of HUD’s programs. Just as we have 

emphasized how important a sound HAP and NRA funding policy is to the success 

of voucher programs, we also believe that the funding structure to support the administrative functions necessary to help families succeed and to enforce housing 

quality standards under the program be established by the Congress. Accordingly, 

for reasons specified above, NAHRO believes that any legislation you adopt should 

require HUD to submit ongoing administrative fee study findings to Congress and 

to interested stakeholders. NAHRO also supports deferring to the existing authorized statute regarding pre-QHWRA fee rates and design under Section 8(q). 

Moving to Work: NAHRO has long advocated for greater program flexibility and 

an expanded Moving to Work (MTW) program in its current form. We fully support 

expanded participation in a well-designed MTW program, as has been done in an 

incremental fashion over the last several years through the appropriations process 

and in similar fashion in legislation sponsored by Representative Gary Miller. 

NAHRO’s first order of business with regard to MTW over the years has been and 

remains to ensure that existing MTW agencies do not have to unravel their valuable 

programs, which they have crafted over several years. We do however strongly support an expansion of MTW to enable program flexibility for many more housing authorities, large and small. If moving and passing long-awaited legislative reforms for 

non-MTW agencies means doing so without a separate MTW title, NAHRO would 

support introduction and passage of a stand-alone and well-crafted MTW bill. 

With respect to MTW language found in AHSSIA, NAHRO and many other 

groups working with HUD collaborated on principles to underpin an expanded MTW 

program. Much of what we agreed to as a group is we understand to be included 

in any final version of AHSSIA. We urge this Subcommittee to carefully consider 

this consensus approach to MTW expansion as one possible approach towards greater program flexibility for many more housing authorities nationwide. However we 

60 

also stand ready to work with you to find additional avenues to encourage program 

innovation and flexibility using the current MTW framework. 

Meaningful Regulatory and Administrative Reforms From HUD Are Long 

Overdue 

I would also like to briefly raise the matter of administrative and regulatory reform which, in our opinion, has been long-overdue at HUD with regard not only to 

the voucher program but other programs administered by housing authorities. 

On May 3, 2011, NAHRO provided an extensive set of recommendations (Document ID: HUD-2011-0037-0024-1 and HUD-2011-0037-0024-2) regarding regulatory 

and administrative reforms in the voucher, public housing and community development programs, in response to President Obama’s Executive Order 13563 titled, 

‘‘Reducing Regulatory Burden; Retrospective Review.’’ On, May 23, 2011, NAHRO 

also sent a letter to HUD to thank HUD for including us in a ‘‘Delivering Together’’ 

briefing focusing on the Department’s intent to identify and implement short-, medium-, and long-term regulatory and statutory reforms to decrease the regulatory 

and administrative burden faced by public housing agencies. At that time, NAHRO 

submitted a smaller list of 27 regulatory and administrative reforms in voucher programs, and also at that time expressed our belief that significant reforms are needed immediately for programs administered by housing authorities. 

We believe that, in addition to the efforts you are making to advance voucher reform legislation, HUD should be prompted by Congress to act with deliberate speed 

to put in place long-overdue regulatory and administrative reforms that would further enhance and expedite a more cost effective and administratively less burdensome voucher program. We ask the Subcommittee to work with us to ensure the 

rapid execution of these reforms that HUD can do now. 

Conclusion 

Mr. Chairman, as this Subcommittee seeks to advance a bill that not only makes 

sense substantively but politically, we urge you to consider and ultimately adopt a 

bill that hews closely to the December 1, 2010, version of SEVRA and reflects some 

of the more thoughtful and constructive provisions in AHSSIA that we have identified today. We see no reason, given the measure of support that the December 1, 

2010, version of SEVRA had and the AHSSIA bill for the most part now has, to either radically depart from language contained in these constructive approaches to 

reform—or worse to start from scratch. The time for discussion has passed; the time 

to act is now! With specific respect to AHSSIA, we are very pleased to see that your 

House colleagues made significant progress on a number of issues important to 

NAHRO, including improvements to the HQS section, and also retained important 

language regarding the establishment of administrative fee rates by Congress. Certainly there is more that this Subcommittee can do to improve upon both bills as 

I have noted but, after almost 10 long years of fits and starts, there is no reason 

to undermine largely viable products that have many if not most program stakeholders on board. 

On behalf of my colleagues at NAHRO, thank you again for the opportunity to 

come before you and express our opinions regarding this vitally important legislation. We look forward to working with you to achieve voucher reform now! 

PREPARED STATEMENT OF HOWARD HUSOCK 

VICE PRESIDENT FOR POLICY RESEARCH, MANHATTAN INSTITUTE

AUGUST 1, 2012 

Thank you Mr. Chairman and thanks to this Committee for devoting its time and 

attention to the important issues of low-income housing policy, which matters so 

much both to the Nation’s most disadvantaged households and to the economies and 

development of our cities. 

The question of how to finance and maintain affordable housing and how to structure and manage our tenant-based low-income housing programs so as to encourage 

self-sufficiency and upwardly mobility, both discussed in the bill recently considered 

by the House, are crucial elements of both U.S. housing policy—and social policy. 

In these remarks, I will focus mainly, on tenant-based programs, particularly the 

Housing Choice Voucher program. 

As the members know, housing vouchers, over the past two decades, have 

emerged as a major program for many of our lowest-income households, roughly 

doubling in size. In FY1998, the Congress appropriated some $9 billion for local 

public housing authorities to distribute in voucher form; most recently, the HUD 

budget includes more than $17 billion for the purpose. Vouchers now serve more 

61 

households than traditional public housing—1.8 million vouchers were issued from 

March 2011 through June 2012, compared with just 1.1 million traditional public 

housing households. Spending on vouchers has even surpassed direct cash benefits 

provided through the Temporary Assistance for Needy Families program of timelimited support. 

One can well understand and sympathize with the reasons for supporting the program’s growth. The challenge for the lowest-income families, those earning 30 percent or less of the median income, to find housing they can afford is substantial, 

although the unfortunate rise in home foreclosures may plausibly make some difference in that regard. It is important, however, to understand the housing choice 

voucher program, in addition, as a key aspect of U.S. social policy—our policy aimed 

at aiding the long-term upward mobility of the most disadvantaged households. 

That traditional goal of social policy—what President Johnson called a ‘‘hand up’’— 

is relevant to the program, in which many of the most vulnerable households are 

enrolled. Like traditional public housing, nonelderly voucher recipients with children are largely single-parent families—a full 94 percent of whom are headed by 

single women. By design, the program serves disadvantaged households of extremely low income—47 percent of voucher recipients are at or below 20 percent of 

the national median income. 

The importance of structuring the program so as to provide aid and incentives 

such that households move toward economic self-sufficiency has, in addition to being 

in keeping with the traditional goal of social programs—as expressed, for instance 

in the 1996 welfare reform act signed by President Clinton, Work—also has a practical dimension. The combination of long waiting lists and the likelihood that appropriations will not be significantly increased and the program expanded, means that 

it behooves policy makers to find ways for the program to help participating families 

move up and out, if only so as to be able to serve others in need. 

It’s in this context that it’s crucial to set goals for the program that go beyond 

administrative efficiency, as important as that is—and include, in addition, such 

metrics as employment, increased household income, and what could be called graduation from the program, or reduced tenure length. To find the best ways to manage 

and structure the program so as to achieve these goals, it makes good sense to give 

the Nation’s extensive network of 3,200 public housing authorities flexibility, based 

on the model of efforts authorized under HUD’s extremely important but modestly 

scaled Moving to Work initiative, which should be made permanent and expanded 

to include as many interested authorities as possible. 

There is precedent for this approach. In the early 1990s, the Nation saw State 

Governments, in their traditional role that Justice Brandeis characterized as that 

of laboratories of democracy, experiment with a variety of approaches to welfare reform. The results guided what then proved to be a successful Federal level reform, 

which has since reduced dependency and increased workforce participation. We have 

seen similar significant local successes among those public housing authorities permitted to date to make use of the flexibility of the Moving to Work program. Notably 

the Atlanta Housing Authority, about which I’ve written extensively in City Journal, used its MTW waiver to link a work requirement with the housing choice 

voucher, coupled with an extensive counseling and workforce preparation program. 

As a result, it has seen an increase in workforce participation among its nonelderly 

population from 14 percent in 1994 to 71 percent today. Atlanta officials believe 

they have created what they term ‘‘a culture of work’’—an historic return to the 

original conception of who public housing authorities should serve. Other authorities, including Cambridge, Mass, and Portland, Oregon, are using Moving to Work 

ways to change their rent structure so as to stop discouraging work—and to encourage tenants to move up and out over time. HUD data shows that, currently, 50 percent of voucher tenants, and 48 percent of tenants in traditional public housing, 

have been in the program for 5 years or longer, a tenure beyond the time limit included in the TANF legislation and with which housing programs might logically 

be aligned. An expansion of Moving to Work could allow other authorities to try 

such experiments—or even to consider, as Philadelphia has, an outright time limit, 

or to tie housing assistance to education, as in Tacoma, Washington. 

Flexibility for local housing authorities must be guided, however, by clear goals 

to be shaped by the Congress and overseen by HUD. These could include increases 

in employment, measurable increases in voucher household income, and reduced 

length of stay in the voucher program itself. As with public education, the requirement to meet standards, coupled with local flexibility in how best to do so, can be 

an effective approach. Local officials know their own labor and real estate markets 

best. It’s unwise to limit the flexibility that comes with Moving to Work, an initiative begun by the Clinton Administration, to just 30 of the Nation’s 3,200 housing 

62 

authorities. It’s a result which could be achieved, as well, through a bloc grant approach to the voucher program generally. 

It is important to acknowledge and keep in mind, as well, as you consider such 

changes, that the voucher program has experienced problems that Moving to Work 

might help to fix. In a 2009 paper for the University of Cincinnati School of Planning entitled ‘‘The Geographic Concentration of Housing Vouchers’’, a team of researchers led by David Varady concluded that a concerted effort by the local housing 

authority to reduce the reconcentration of poverty households through the voucher 

program—a goal widely discussed—had not succeeded. The authors found ‘‘vouchers 

clustering in areas that are poor and/or getting poorer, including ‘‘emerging hot 

spots’’—and reported, too ‘‘neighborhood alarm.’’ The study cites and confirms journalistic accounts, including my own in City Journal and that of Hannah Rosin in 

The Atlantic, which have raised similar concerns. In discussing what the authors 

call the ‘‘implications for national policy’’, they conclude that ‘‘studies combining the 

qualitative and quantitative perspectives are urgently needed’’. Policy innovation, 

permitted at the local level, can serve as the foundation for such research, as policy 

makers, over the long-term, consider whether housing-specific assistance, and on 

what terms, is the best way to assist low-income households. 

Finally, I’d like to address briefly the proposal, also discussed in the House bill’s 

language, to convert public housing capital and operating subsidies into project-specific vouchers, as a both a means to preserve affordable housing developments in 

their current use and to facilitate increased investment of private capital to reduce 

an estimated $30 billion in maintenance backlogs. The rationale for doing so, in a 

time of serious maintenance needs and budget shortfalls, is obvious—and may provide a useful additional tool for public housing officials facing serious deferred maintenance. I would urge, however, that Members of this Committee be cautious in a 

too-broad embrace of such plans. First, public policies which use public funds, tax 

credits, or regulatory mandates to influence the allocation of private capital risk reducing the availability of capital for other uses which may contribute more to economic growth and wealth creation—in ways which ultimately benefit lower-income 

families more than might affordable housing preservation. Similarly, the designation of specific real estate parcels for affordable housing purposes for the long-term 

risks inducing municipalities to forestall the use of such parcels for the highest and 

best economic uses—again in ways that may uplift the economic prospects of all citizens. The proposed voucher-based maintenance financing approach for public housing is impressively imaginative—but should not been seen, in my view, as a way 

to preserve, unit-by-unit—all public and subsidized housing. Better, in my own view, 

for the Congress, through HUD, also to encourage additional approaches which 

could include, for instance, the sale of high-value parcels currently owned by local 

housing authorities so as to create locally based maintenance endowments for remaining units. Let’s be guided, both in how much public housing we preserve, and 

how we set the regulations for housing vouchers, not by a narrow goal of preservation or expansion but by a broad determination to help uplift low-income households 

and improve the economies of our cities. 

PREPARED STATEMENT OF WILL FISCHER 

SENIOR POLICY ANALYST, CENTER ON BUDGET AND POLICY PRIORITIES

AUGUST 1, 2012 

Thank you for the opportunity to testify. I am Will Fischer, Senior Policy Analyst 

at the Center on Budget and Policy Priorities. The Center is an independent, nonprofit policy institute that conducts research and analysis on a range of Federal and 

State policy issues affecting low- and moderate-income families. The Center’s housing work focuses on improving the effectiveness of Federal low-income housing programs, and particularly the Section 8 housing voucher program. 

It is commendable that the Subcommittee is holding a hearing on streamlining 

and strengthening rental assistance. The proposed Affordable Housing and Self-Sufficiency Improvement Act (AHSSIA), Section 8 Savings Act (SESA), and Section 8 

Voucher Reform Act (SEVRA) all contain important, timely measures to strengthen 

the voucher program and other major rental assistance programs. The reforms in 

these bills would sharply reduce administrative burdens for State and local housing 

agencies and private owners, establish voucher funding rules that would enable 

housing agencies to manage funds more efficiently, strengthen work supports, and 

generate large Federal savings. 

This testimony focuses on seven core reforms that should receive top priority for 

enactment. Each of these measures appears in some form in the version of AHSSIA 

63 

1My testimony focuses on these versions—the most recent public version of each bill—except 

where otherwise noted. Since SESA was circulated by the current leadership of the House Financial Services Committee earlier in this Congress, I generally focus on the Committee’s later 

AHSSIA bill instead. A detailed side-by-side comparing AHSSIA, SEVRA, and current law is 

available at http://www.cbpp.org/files/5-10-12-SEVRA-AHSSIA-CurrentLaw-Comparison.pdf. 2Diana Becker Cutts, MD, ‘‘U.S. Housing Insecurity and the Health of Very Young Children’’, 

American Journal of Public Health, August 2011, Vol. 101, No. 8, p. 1508; Michelle Wood, Jennifer Turnham, and Gregory Mills, ‘‘Housing Affordability and Well-Being: Results From the 

Housing Voucher Evaluation’’, Housing Policy Debate 19:367–412 (2008). 3 Joint Center for Housing Studies of Harvard University, ‘‘America’s Rental Housing: Meeting Challenges, Building on Opportunities’’, April, 2011, p. 5 and table A-9, http:// 

www.jchs.harvard.edu/sites/jchs.harvard.edu/files/americasrentalhousing-2011.pdf. 4 James A. Riccio, ‘‘Subsidized Housing and Employment: Building Evidence of What Works’’, 

in Nicolas P. Retsinas and Eric S. Belsky, eds., Revisiting Rental Housing, Joint Center for 

Housing Studies and Brookings Institution Press, 2008. 5Maya Brennan, ‘‘The Impacts of Affordable Housing on Education: A Research Summary’’, 

Center for Housing Policy, May 2011, http://www.nhc.org/media/files/InsightslHousingAndEducationBrief.pdf. 6Gretchen Locke, Ken Lam, Meghan Henry, Scott Brown, ‘‘End of Participation in Assisted 

Housing: What Can We Learn About Aging in Place?’’ Abt Associates Inc., February 2011, available at: http://www.huduser.org/publications/pdf/ 

LockelAgingInPlacelAssistedHousingRCR03.pdf. 7For summaries of findings and references, see U.S. Interagency Council on Homelessness, 

‘‘Opening Doors: Federal Strategic Plan To Prevent and End Homelessness, 2010’’, pp. 18–19, 

http://www.usich.gov/PDF/OpeningDoorsl2010lFSPPreventEndHomeless.pdf; and Michael 

Continued 

circulated by the Financial Services Committee on April 13, 2012, and the version 

of SEVRA circulated by the Banking and Financial Services Committees on December 1, 2010. 1 These high-priority reforms would: 

• Simplify rules for setting tenant rent payments, while continuing to cap rents 

at 30 percent of a tenant’s income; 

• Streamline voucher housing quality inspections to encourage private owners to 

participate in the program; 

• Establish a stable, fair voucher funding system to enable agencies to use funds 

more efficiently and better cope with shortfalls; 

• Allow more working poor families to qualify for vouchers by modestly raising 

income targeting limits; 

• Strengthen the Family Self-Sufficiency program, which offers housing assistance recipients job counseling and incentives to work and save; 

• Provide added flexibility to ‘‘project-base’’ vouchers to support affordable housing development and preservation; 

• Make the rental assistance admissions process fairer by limiting screening to 

criteria related to suitability as a tenant. 

My testimony also discusses several other provisions that have been included in 

one or more of the reform bills. 

Reform Would Build On Strengths of the Rental Assistance Programs 

The Nation’s rental assistance programs help more than four million low-income 

households afford decent housing. The great majority of these households are senior 

citizens, people with disabilities, and working poor families with children. As shown 

in the table attached to this testimony, rental assistance units are spread among 

the 50 States and across rural and urban areas. 

Rigorous research has shown that rental assistance can sharply reduce the incidence of homelessness and housing instability—problems that have been shown to 

have serious harmful effects on children’s health and development. 2 Families that 

receive assistance to ease rent burdens also have more funds available for other 

basic needs, such as food, medication, child care, and transportation, and may be 

able to save or invest in education to help lift themselves out of poverty. 3

Housing assistance produces positive indirect effects, as well. Studies suggest that 

work-promoting initiatives are more effective for families with affordable housing, 4

and a growing body of research suggests that stable, affordable housing may provide 

children with better opportunities for educational success. 5 Affordable housing combined with supportive services can help the elderly and people with disabilities retain their independence and avoid or delay entering more costly institutional care 

facilities. 6 The evidence of health care and other savings from providing affordable 

housing and services to homeless individuals with chronic health problems is particularly compelling. 7

64 

Nardone, Richard Cho, and Kathy Moses, ‘‘Medicaid-Financed Services in Supportive Housing 

for High-Need Homeless Beneficiaries: The Business Case’’, Center for Health Care Strategies, 

Inc., June 2012, available at http://www.rwjf.org/files/research/74485.business.case.pdf. 8 Jens Ludwig, et al., ‘‘Neighborhoods, Obesity, and Diabetes—A Randomized Social Experiment’’, New England Journal of Medicine, 365:16, October 2011, http://www.nejm.org/doi/full/ 

10.1056/NEJMsa1103216; Brian A. Jacob, Jens Ludwig, Douglas L. Miller, ‘‘The Effects of 

Housing and Neighborhood Conditions on Child Mortality’’, NBER Work Paper No. 17369, National Bureau of Economic Research, August 2011, http://www.nber.org/papers/w17369. 9 Heather Schwartz, ‘‘Housing Policy is School Policy’’, The Century Foundation, 2010, http:// 

tcf.org/publications/pdfs/housing-policy-is-school-policy-pdf/Schwartz.pdf. 10Many fixed-income benefits, such as Social Security and SSI, typically increase annually 

due to cost-of-living adjustments. To avoid a loss of revenue from this streamlined option, agencies would be required to assume that in the intervening 2 years these tenants’ incomes rose 

by a rate of inflation specified by HUD. 

Research has found additional benefits when housing assistance enables low-income families to live in neighborhoods with lower poverty rates, including sharply 

fewer deaths from disease or accidents among girls and lower rates of obesity and 

diabetes. 8 Where housing policies have allowed low-income children to attend highperforming, economically integrated schools over the long term, their math and 

reading test scores are significantly better than comparable children who attended 

higher-poverty schools. 9

The core reforms in SEVRA and AHSSIA would build on this record of success. 

Fourteen years have passed since the enactment of the Quality Housing and Work 

Responsibility Act (QHWRA) in 1998, the last major authorizing legislation affecting 

the voucher and public housing programs. As with any program, adjustments are 

needed over time to reflect changed circumstances and lessons learned. 

Reforms that stretch limited dollars to assist more families or avoid painful cuts 

are especially urgent today, when budgets are tight but unemployment, poverty, and 

homelessness are high. The Congressional Budget Office (CBO) estimated that the 

December 2010 version of SEVRA would reduce the budget authority needed to fund 

the current level of housing assistance by more than $700 million over 5 years. Financial Services Committee staff have indicated that the April 2012 version of 

AHSSIA (which included additional cost saving measures) would save at least $1.5 

billion. These estimates do not attempt to include administrative savings, which 

could lower funding needs by an added several hundred million dollars over 5 years. 

Simplifying Rules for Determining Tenants’ Rent Payments 

Tenants in HUD’s housing assistance programs generally must pay 30 percent of 

their income for rent, after certain deductions are applied. The rent streamlining 

provisions in AHSSIA and SEVRA maintain this rule, but would streamline determination of tenants’ incomes and deductions. As a result, the bills would reduce burdens on housing agencies, property owners, and tenants. The changes would also reduce the likelihood of errors in rent determinations and strengthen work incentives 

for tenants. 

Most significantly, the bills would: 

• Reduce the frequency of required income reviews. Currently, agencies and owners must review income annually for all tenants. AHSSIA and SEVRA would 

allow agencies and owners to limit reviews to once every 3 years for households 

that receive most or all of their income from fixed sources such as Social Security or SSI and consequently are unlikely to experience much income variation. 10

Today agencies and owners also must adjust rents between annual reviews at the 

request of any tenant whose income drops. AHSSIA and SEVRA would require adjustments only when a family’s annual income drops by 10 percent or more, making 

such ‘‘interim’’ reviews less common but still providing adjustments when tenants 

would otherwise face serious hardship. The bills also would require interim adjustments for income increases exceeding 10 percent, except that adjustments for earnings increases would be delayed until the next annual review to strengthen work 

incentives. 

Together, these changes would sharply reduce the number of income reviews that 

agencies and owners must conduct. This would substantially lower administrative 

costs, since income reviews are among the most labor-intensive aspects of housing 

assistance administration. 

• Simplify deductions for the elderly and people with disabilities. Currently, if the 

household head (or his or her spouse) is elderly or has a disability, housing 

agencies and owners must deduct medical expenses and certain disability assistance expenses above 3 percent of the household’s income from income for 

65 

purposes of determining the household’s rent. Agencies and owners report that 

this deduction is difficult to administer, since they must collect and verify receipts for all medical expenses. It also imposes significant burdens on elderly 

people and people with disabilities, who must compile and submit receipts that 

may contain highly personal information. Largely for these reasons, many 

households eligible for the deduction do not receive it. By contrast, a second deduction targeted to the same groups—a $400 annual standard deduction for 

each household where the head or spouse is elderly or has a disability—is quite 

simple to administer. 

AHSSIA and SEVRA would increase the threshold for the medical and disability 

assistance deduction from 3 percent of annual income to 10 percent. This would reduce the number of people eligible for the deduction—and therefore the number of 

itemized deductions that would need to be determined and verified—while still providing some relief for tenants with extremely high medical or disability assistance 

expenses. At the same time, the bills would increase the easy-to-administer standard deduction for the elderly and people with disabilities, to $675 annually in 

SEVRA and $525 annually in AHSSIA, and index it for inflation. 

In addition to reducing processing burdens for agencies, owners, elderly people, 

and people with disabilities, this change is likely to reduce payment errors substantially. HUD studies have found that the medical and disability expense deduction 

is one of the most error-prone components of the rent determination process, while 

errors in the standard deduction are rare. 

The higher $625 standard deduction in SEVRA would be preferable, since it would 

come closer to fully offsetting rent increases (on average across all families) from 

the scaled back medical expense deduction (although it would also result in somewhat lower savings). Some individual households would see higher or lower monthly 

rents, but the changes would generally be modest. Congress could provide added 

protection for tenants who are adversely affected by allowing HUD to establish a 

hardship exemption policy (as AHSSIA would do) and delaying the effective date of 

the change to allow tenants to find other ways to cover out-of-pocket medical expenses. 

• Simplify deductions for families with children. AHSSIA and SEVRA would scale 

back an existing deduction for child care expenses—which evidence suggests is 

implemented inconsistently—by allowing deductions only of expenses above 5 

percent of income (rather than all reasonable expenses). At the same time, it 

would increase from $480 to $525 a simple annual deduction that families receive for each child or other dependent, and index it for inflation. The dependent deduction recognizes the larger share of family income required to cover 

nonshelter expenses when a family has more children. 

• Base rents on a tenant’s actual income in the previous year. Currently, rents are 

based on a tenant’s anticipated income in the period that the rent will cover, 

usually the coming 12 months. Except when a family first begins receiving 

housing assistance, AHSSIA and SEVRA would require agencies generally to 

base rents on actual income in the previous year. This would give tenants an 

incentive to increase their earnings, since such an increase would not affect 

their rent for as long as a year. It also would simplify administration, both by 

making it easier for agencies and owners to use tax forms and other year-end 

documentation to verify income and by reducing the need for midyear rent adjustments for tenants whose earnings change during the year. 

• Limit utility allowances based on family size and composition. AHSSIA contains 

a provision to limit utility allowances in the voucher program based on the 

number of bedrooms a family is eligible for given its composition, rather than 

the actual size of the unit. Today families are permitted to rent units larger 

than they are eligible for, but the cap on the total housing costs the voucher 

covers (that is, the payment standard) does not rise as a result. Adopting the 

AHSSIA limit on utility allowances would generate savings and avoid providing 

families incentives to rent larger units than they need. 

• Allow housing agencies to use income data gathered by other programs. AHSSIA 

and SEVRA contain a provision that would allow State and local housing agencies and owners to rely on income determinations carried out under SNAP (formerly food stamps) and other Federal means-tested programs, without separate 

verification. Currently, housing agencies and owners must determine and verify 

income independently, even though this duplicates work already being carried 

out by other agencies. Allowing housing agencies to rely on income determinations made by SNAP agencies would ease their administrative burdens considVerDate Nov 24 2008 09:17 Apr 26, 2013 Jkt 048080 PO 00000 Frm 00069 Fmt 6621 Sfmt 6621 L:\HEARINGS 2012\08-01 & 12-11 HUD S RENTAL HOUSING ASSISTANCE PROGRAMS, 
66 

11The flat rent option was authorized by the Quality Housing and Work Responsibility Act 

of 1998 (QHWRA). The AHSSIA provision would also apply to ‘‘ceiling’’ rents, which were established prior to the enactment of QHWRA and are subject to somewhat different rules. 12 Abt Associates et al, Study of Rents and Rent Flexibility, prepared for HUD Office of Public 

and Indian Housing, May 26, 2010, http://www.huduser.org/publications/pdf/ 

Rent%20StudylFinal%20Reportl05-26-10.pdf. 

erably, since a large portion of housing assistance recipients also receive SNAP 

benefits. 

AHSSIA, however, does not include a provision from the December 2010 version 

of SEVRA requiring State SNAP agencies to make available to housing agencies income data for families participating in both programs. It is important that Congress 

include this requirement, since without it many SNAP agencies may not provide the 

needed data. 

Flat Rent Changes Offer Promising Way To Raise Revenues 

To encourage a mixture of incomes among public housing residents, current law 

permits residents to elect to pay a ‘‘flat rent.’’ This policy benefits residents with 

the highest incomes (who pay less than 30 percent of their income for housing under 

the policy) but has been considered reasonable because HUD rules require that flat 

rents be set at the ‘‘estimated rent for which the [agency] could promptly lease the 

public housing unit’’—that is, at the approximate market rent. Data suggest, however, that existing flat rents are well below market rents in some areas, which 

raises Federal costs and can increase funding shortfalls for local agencies. 

AHSSIA includes a statutory change proposed in the Administration’s 2012 budget to require agencies to set flat rents no lower than 80 percent of the HUD fair 

market rent for the area. 11 HUD estimates that the provision would reduce public 

housing operating subsidy needs by $150 million in the first year and by more than 

$400 million per year once the proposal is fully phased in. 

As proposed by HUD, AHSSIA would require local agencies to implement the new 

policy no later than September 30, 2013, which would allow agencies some time to 

phase the policy in. In addition, the bill limits any increases in rental payments by 

affected households to 35 percent per year. 

Minimum Rent Increase Would Harm the Poorest Tenants 

The April version of AHSSIA contains a provision not included in SEVRA increasing to $69.45 a month the ‘‘minimum rents’’ that the lowest income housing assistance recipients can be required to pay, and indexing this amount for inflation. 

Under current law, housing agencies have the option of setting minimum rents for 

voucher holders and public housing residents up to $50. HUD also has authority to 

set minimum rents up to $50 in project-based Section 8 units, and currently has 

set that level at $25. 

The April AHSSIA provision makes two significant improvements over the minimum rent proposal in the earlier version of AHSSIA that a House Financial Services subcommittee passed on February 7, 2012: 

• The subcommittee-passed bill would have required all housing agencies and 

owners to charge minimum rents of $69.45, eliminating the discretion that exists under current law. By contrast the April AHSSIA provision would permit 

housing agencies and owners to set minimum rents below $69.45 for ‘‘good 

cause,’’ unless HUD disapproves the lower rent. 

• The subcommittee-passed bill made no significant changes to existing protections for families that would face hardship if they were required to pay minimum rents. A 2010 HUD-sponsored study found that these protections help few 

families: 82 percent of agencies reported providing exemptions to less than 1 

percent of families subject to minimum rents, and only 5 percent of agencies 

said they had exempted more than a tenth of affected families. 12 The April 

AHSSIA bill improves the hardship requirements to increase the chances that 

poor families facing hardship will be exempted. 

Despite these improvements, the April AHSSIA provision is still likely to harm 

many of the Nation’s most vulnerable families and individuals. As many as 500,000 

households could be required to pay higher rents, including families with 725,000 

children. While the improvements described above would protect some families, 

many are still likely to fall through the cracks, placing them at risk of severe hardship and even homelessness. Moreover, is not clear what the rationale for the increase is. Congress should omit it in final rental assistance reform legislation. 

67 

Rent Demonstration Could Be Useful, but Restrictions Should Be Tightened 

AHSSIA and SEVRA would authorize HUD to conduct a limited demonstration 

of alternative rent policies. Such a demonstration is potentially beneficial. Today’s 

rent rules generally work well, providing sufficient help to enable the neediest families to afford housing while not giving higher-income families more subsidy than 

they need. In addition, the current system maintains largely identical rules across 

programs and localities, making it easier for voucher holders to move from one community to another (for example to pursue a job opportunity), for private-sector owners and investors to participate in multiple programs and operate in multiple jurisdictions, and for HUD to provide effective oversight. 

Most major changes—and particularly those that would result in sharply higher 

or lower subsidies for certain families—would carry substantial risks and tradeoffs. 

It is possible, however, that some substantial changes would have significant benefits that would justify enacting them on the Federal level. For example, a policy of 

disregarding some percentage of earned income would carry added costs, but might 

encourage sufficient increases in earnings to offset a sizable share of the cost and 

justify the change. A demonstration could offer an opportunity to rigorously test policy alternatives to determine their costs and benefits relative to the current rules. 

HUD is already conducting a rent demonstration at a subset of MTW agencies, but 

would need additional statutory authority to extend it to other agencies. 

However, the rent demonstration in AHSSIA and SEVRA should be strengthened 

in important ways. It should provide HUD broader flexibility to identify promising 

policies, limit the length of the demonstration to avoid allowing wasteful or harmful 

policies to remain in place indefinitely, explicitly require an experimental evaluation, and clarify that the ‘‘limited’’ number of families that can be subject to alternative policies should be no more than the number needed to yield statistically valid 

results. 

Streamlining Inspections To Encourage Participation by Private Owners 

The voucher program requires that vouchers be used only in houses or apartments that meet Federal quality standards. AHSSIA and SEVRA would allow agencies to modestly change the inspection process used to ensure that units meet those 

standards. The changes would ease burdens on agencies and encourage landlords to 

rent apartments to voucher holders. 

Most significantly, AHSSIA and SEVRA would allow agencies to inspect apartments every 2 years instead of annually. In addition, the bills would allow agencies 

to (1) rely on recent inspections performed for other Federal housing programs, and 

(2) make initial subsidy payments to owners even if the unit does not pass the initial inspection, as long as the failure resulted from non- life-threatening conditions. 

Defects would have to be corrected within 30 days of initial occupancy for the payments to continue. These provisions would encourage owners to participate in the 

voucher program by minimizing any financial loss due to inspection delays. They 

also would enable voucher holders, who in some cases are homeless or experience 

other severe hardship, to move into the unit more quickly than under current rules. 

Today, when an inspection of a unit occupied by a voucher holder finds a violation, the housing agency is permitted to temporarily halt subsidy payments if the 

owner fails to address the violation in a timely manner, and ultimately terminate 

the subsidy if the defects are not adequately repaired. AHSSIA and SEVRA would 

retain this authority and establish a series of requirements regarding the rights of 

tenants and other aspects of subsidy abatement and termination. 

SEVRA also includes a beneficial requirement, which Congress should enact, for 

housing agencies to provide assistance to help tenants find a new unit and relocate 

if the subsidy to their unit is terminated because of an inspection violation. AHSSIA 

would make this assistance optional. 

Stabilizing Voucher Funding Rules 

One of the most important goals of authorizing legislation concerning the voucher 

program should be to establish a stable, fair, efficient policy for distributing funds 

to renew voucher subsidies to the approximately 2,400 State and local agencies that 

administer the program. This would enable those agencies to assist more families 

within the level of resources provided in annual appropriations bills than would otherwise be possible. 

For the last 9 years, appropriations acts have changed renewal funding policies 

every several years. Such instability creates uncertainty and makes many agencies 

reluctant to use the funds they have to serve the number of families Congress has 

authorized, out of fear that they will not receive sufficient renewal funding to maintain payments to landlords. As a result, only about 92 percent of authorized vouchVerDate Nov 24 2008 09:17 Apr 26, 2013 Jkt 048080 PO 00000 Frm 00071 Fmt 6621 Sfmt 6621 L:\HEARINGS 2012\08-01 & 12-11 HUD S RENTAL HOUSING ASSISTANCE PROGRAMS, 
68 

ers are in use, compared to about 97 percent before the changes in renewal funding 

policy began—a loss of assistance to about 100,000 families. The reform bills include 

a package of changes that would stabilize and strengthen renewal funding policy. 

• Stable funding formula. AHSSIA and SEVRA would establish as a permanent 

part of authorizing law the policy in recent appropriations bills of basing each 

agency’s funding on the cost of the vouchers it used in the previous year, adjusted for inflation and certain other factors. This approach forces agencies to 

manage within a limited budget, while also ensuring that each agency’s funding 

level matches its actual needs. 

• Stable reserve and offset policy. AHSSIA and SEVRA would assure State and 

local housing agencies that they can maintain a funding reserve of at least 6 

percent of the renewal funding for which they are eligible, but permit HUD to 

‘‘offset’’ (that is, deduct from the agency’s funding) reserves above that level. 

AHSSIA improves on the SEVRA offset policy by extending it to cover MTW 

agencies in addition to non-MTW agencies; this avoids unfairly disadvantaging 

non-MTW agencies. 

In the current funding environment, when agencies may fear that Congress will 

not provide sufficient new funding to support all vouchers in use, a predictable reserve level provides the cushion agencies need to reissue vouchers to needy applicants on the waiting list when families leave the program and be confident that 

they will have sufficient funds to sustain the vouchers. At the same time, making 

clear that HUD will have authority to offset reserves beyond the permitted amount 

provides a strong incentive for agencies to put excess funds to use assisting families. 

• Permitting agencies to assist as many families as possible with available funds. 

AHSSIA and SEVRA would encourage agencies to reduce the cost of voucher 

subsidies and stretch their voucher funds to serve as many families as possible 

by restoring flexibility that existed prior to 2003 to assist families beyond the 

agency’s ‘‘authorized voucher cap.’’ Under a policy adopted in annual appropriations acts since 2003, agencies are penalized if they use more than their authorized number of vouchers in a year, even if they can do so with available funds 

by reducing per-voucher costs. This policy has pushed many agencies to use 

substantially fewer than their authorized number of vouchers, out of fear of exceeding the cap. 

AHSSIA and SEVRA would remove this chilling effect and assure agencies that 

if they took steps to limit costs, they could use any savings to provide vouchers to 

more families even if this pushes them above their authorized voucher level. Vouchers above the authorized level that are supported by unused prior-year funds would 

not be counted for determining the agency’s future funding level, so this incentive 

would not increase program costs. 

• Efficient use of funds above renewal formula amounts. When Congress passes 

appropriations bills in a timely manner, it sets the voucher funding level before 

all the data needed to know the precise amount agencies will be eligible for 

under the renewal formula are available. In recent years, when funding has exceeded the amount needed HUD has been required to distribute the extra funds 

pro rata to all agencies. HUD could use these funds more efficiently if it had 

authority to allocate them to meet unforeseen needs, reward high performance, 

or for other purposes. SEVRA provides HUD broad authority to make such allocations, while AHSSIA provides more limited discretion. The SEVRA provision 

would be preferable, but Congress should enact at least the AHSSIA provision. 

Per-Voucher Costs Have Risen More Slowly Than Housing Costs in the Private Market 

While AHSSIA and SEVRA would create important incentives to keep per-voucher 

costs low, it is important to note that this would build on the voucher program’s 

already successful record of restraining costs. Per-voucher costs have generally risen 

at a slower rate than housing costs in the private market. HUD-determined Fair 

Market Rents (FMRs), which are based in market rents for standard-quality unassisted units, increased by 19 percent from 2005 to 2010. As shown in Figure 1, during that same period per-voucher costs increased by less than 16 percent. 

A central reason for this is that housing agencies controlled voucher costs through 

their ability to set payment standards, which cap voucher subsidies and can be set 

anywhere from 90 to 110 percent of the FMR (and outside that range under some 

circumstances). This explanation receives support from HUD data showing that, on 

average, voucher payment standards declined in relation to FMRs from 2005 to 

2010. 

69 

13 A separate provision of SEVRA (but not AHSSIA) would prohibit families from continuing 

to receive assistance if their income rises to a much higher level (generally above 80 percent 

of local median income). Currently, there is no income limitation after admission. Under 

SEVRA, owners and agencies could opt not to enforce this new policy in project-based Section 

8 and public housing. And families with incomes above 80 percent of median in most areas no 

longer qualify for assistance under the voucher program because 30 percent of their adjusted 

income—their required contribution—exceeds the maximum rent a voucher can cover. Nonetheless, because the SEVRA policy would terminate assistance for some higher-income families 

(who would then typically be replaced by lower-income families who require larger subsidies), 

CBO estimated that it would cost $209 million over 5 years. 

By incorporating an improved voucher renewal funding policy in permanent law, 

AHSSIA and SEVRA would provide agencies—as well as families with vouchers and 

private owners—with more confidence that renewal funding needs will be met in future years, which is particularly important to maintain program effectiveness in the 

current fiscal environment. This approach would not weaken Congress control over 

the cost of the program. Congress would still determine the amount of annual program funding, and if the funds appropriated in a given year were insufficient to 

fully fund the renewal formula, HUD would reduce each agency’s funding by the 

same percentage so funds would still be allocated based on agencies’ relative needs. 

The provisions in the bills would simply ensure that, for any given level of funding, 

more families would receive the important benefits that vouchers have been shown 

to provide. 

Easing Income Targeting Rules To Help More Working-Poor Families 

Currently, 75 percent of vouchers and 40 percent of project-based Section 8 and 

public housing units must be allocated to households with incomes at or below 30 

percent of the median income in the local area at the time they enter the program. 

AHSSIA and SEVRA would adjust these criteria to require that those vouchers and 

units be allocated to households with incomes at or below 30 percent of local median 

income or the Federal poverty line, whichever is higher. Neither this revised requirement nor current law restricts a family’s income after it is admitted. 13

This change would give housing agencies greater flexibility to target working-poor 

families. Some agencies in low-income areas have expressed concern that the current targeting criteria prevent them from assisting these families. At the same time, 

the change would maintain the emphasis on assistance for the poor. CBO has estimated that the reduction in subsidy needs that would result from easing targeting 

rules would reduce funding needs by $1.14 billion over 5 years, making it the largest source of savings in the bills. 

70 

The only difference between the bills’ targeting provisions is that AHSSIA fixes 

language in SEVRA that could allow targeting in project-based Section 8 developments in Puerto Rico and other U.S. territories to be raised excessively. The Federal 

poverty line is not designed to apply in U.S. territories, and using it to target housing assistance there would raise the targeting threshold far above 30 percent of the 

local median income and shift assistance away from the neediest families. For this 

reason, both AHSSIA and SEVRA seek to exempt the territories from the targeting 

change, but the SEVRA exemption applies only to ‘‘in the case of public housing 

agencies’’ located in a U.S. territory. This would allow sharp targeting increases in 

project-based Section 8 developments, which generally are not administered by public housing agencies. Congress should adopt the more complete AHSSIA exemption. 

Strengthening the Family Self-Sufficiency Program 

The Family Self-Sufficiency (FSS) program encourages work and saving among 

voucher holders and public housing residents through employment counseling and 

financial incentives. Both AHSSIA and SEVRA establish a stable formula to allocate 

funds to cover administrative costs of FSS programs. This formula would replace a 

competitive process that has made funding unpredictable and disrupted administration of local FSS programs. 

Unfortunately, residents of units assisted through the project-based Section 8 program are ineligible for FSS today. AHSSIA (but not SEVRA) corrects this omission, 

enabling families receiving any type of Section 8 assistance as well as public housing residents to benefit from FSS. Offering participation in the FSS program to 

project-based Section 8 tenants would be optional for property owners. Generally, 

such tenants would participate in an FSS program operated by a public housing 

agency, if one is available that will admit the families. Owners of properties with 

project-based Section 8 contracts could also use funds in their HUD-required ‘‘residual receipts accounts’’ to operate an FSS program independently if it serves at least 

25 participants. 

AHSSIA also contains other beneficial FSS provisions, including a requirement 

that housing agencies with 500 or more voucher and public housing units offer or 

expand FSS programs if sufficient funds are available. 

Facilitating Use of Project-Based Vouchers 

Both AHSSIA and SEVRA would make it easier for a housing agency to enter into 

agreements with owners for a share of its vouchers to be used at a particular housing development. Through such ‘‘project-basing,’’ agencies can, for example, partner 

with social service agencies to provide supportive housing to formerly homeless people or support development of mixed-income housing in low-poverty neighborhoods 

with strong educational or employment opportunities. 

Residents of units with project-based voucher assistance have the right to move 

with a voucher after 1 year, using the next voucher that becomes available when 

another family leaves the program. (When this occurs, a voucher remains attached 

to the housing development; the family moving out of the development receives a 

separate voucher.) This ‘‘resident choice’’ feature and other policies make the 

project-based voucher option significantly different from earlier programs that provided project-based assistance. 

AHSSIA and SEVRA increase the percentage of an agency’s voucher assistance 

that can be project-based from 20 percent to 25 percent, if the added 5 percent is 

used in areas where vouchers are difficult to use, to house homeless families or individuals, or to provide supportive housing to people with disabilities. AHSSIA adds 

units that house veterans or the elderly to the categories that qualify for this added 

authority. In SEVRA, agencies would be permitted to project-base the higher of 25 

percent of their authorized vouchers or 25 percent of their voucher funding, giving 

greater flexibility to housing agencies that are able to keep project-based voucher 

costs low. AHSSIA would base the limit strictly on the percentage of the agency’s 

authorized vouchers. 

In addition, the bills would permit housing agencies to commit to project-based 

voucher contracts with a term of 20 years (the term HUD permits for contracts 

under the separate project-based Section 8 program), rather than the 15-year maximum permitted today. The bills would also permit owners to establish and maintain site-based waiting lists subject to civil rights and other requirements, allow 

agencies to provide project-based vouchers in the greater of 25 percent of units or 

25 units in a project, and permit 40 percent of the units in a project to have projectbased vouchers in areas where vouchers are difficult to use or the poverty rate is 

71 

14 Both today and under AHSSIA and SEVRA, agencies can place project-based vouchers in 

100 percent of units in developments that assist the elderly or people with disabilities or provide 

supportive services to residents. 

20 percent or less. 14 These policy changes would help agencies increase the effectiveness of the voucher program in rural and suburban areas, where rentals are frequently scarce and properties tend to be small, and in low-poverty areas in all types 

of locations. 

Protection Against Arbitrary Screening of Housing Assistance Recipients 

Housing agencies and owners must screen housing assistance applicants based on 

several federally required criteria, and can opt to establish additional screening criteria. AHSSIA and SEVRA would make several changes to the screening process for 

the housing voucher program, including limiting optional screening criteria to those 

directly related to the family’s ability to meet the obligations of the lease and requiring housing agencies to consider mitigating factors before denying assistance. These 

important improvements would prevent, for example, denial of assistance to a family with a good record of paying rent on time but (like many poor families) a weak 

credit history for other reasons, and would make it easier to provide housing vouchers to homeless people and others with an urgent need for assistance who today 

might be denied help for arbitrary reasons. 

Unfortunately, the current AHSSIA draft drops a provision of some versions of 

SEVRA that would have made similar (and equally important) changes in the public 

housing and project-based Section 8 programs. Congress could extend the changes 

to those programs by restoring the omitted provisions or simply by giving HUD authority to establish common requirements for all rental assistance programs. 

Both AHSSIA and SEVRA also would add an important protection for families 

being shifted from assistance under the public housing or HUD multifamily programs to housing vouchers due to the elimination of the existing assistance for the 

properties in which they reside. The bills recognize that such families are not new 

to HUD assistance and should be considered continuing participants rather than 

new applicants subject to initial screening. In addition to protecting families, these 

changes also would reduce administrative burdens for housing agencies. 

Other Provisions 

In addition to these seven core reforms, a series of other provisions appear in 

SEVRA, AHSSIA, or both. Several of these provisions are discussed below: 

• Local flexibility to adjust voucher payments to accommodate the special needs 

of people with disabilities. Housing agencies today can allow people with disabilities to use vouchers to rent more expensive units than is permitted for 

other families, if this is necessary to accommodate their disability. If this requires a payment standard above 110 percent of the FMR, however, the agency 

must obtain special approval from HUD. This can create delays that make it 

much more difficult for people with disabilities to use vouchers. Accessible units 

are often more costly than a typical unit in an area, either because few such 

units exist or because they require added investments by owners. 

SEVRA and AHSSIA would allow agencies to provide exceptions up to 120 percent 

of the FMR for this purpose without approval from HUD. Because these exceptions 

would be needed for only a small share of vouchers, this important provision’s cost 

would be minimal. 

• Use of vouchers in manufactured housing. AHSSIA drops a beneficial SEVRA 

provision that would allow vouchers to be used to cover loan payments, insurance payments, and other periodic costs of buying a manufactured home, in addition to the cost of renting a space on which to place the home. The combined 

payments would, however, be subject to the same subsidy limits that apply to 

other vouchers. 

Currently, vouchers can be used to cover the full range of periodic home ownership costs for the purchase of a traditional home or a manufactured home set on 

land also purchased by the family. But if a family rents the space for a manufactured home, which is common in some States, the voucher subsidy is limited to 

about 40 percent of the assistance it could otherwise provide, and can only cover 

the space rental costs and not the costs of purchasing the home. The SEVRA provision would allow vouchers to be used effectively in a segment of the housing market 

that in some areas is the most readily available source of affordable housing—and 

that for many families offers the most realistic avenue to home ownership. 

72 

15For further discussion of the risks of posed by MTW expansion, see Douglas Rice and Will 

Fischer, Proposal to Greatly Expand ‘‘Moving to Work’’ Initiative Risks Deep Cuts in Housing 

Assistance Over Time, available at http://www.cbpp.org/files/1-10-12hous.pdf, and Will Fischer, Expansion of HUD’s Moving to Work Demonstration Is Not Justified, available at http:// 

www.cbpp.org/cms/index.cfm?fa=view&id=3590. 

• Fair Market Rents. AHSSIA and SEVRA contain identical provisions that would 

make modest improvements to the process for setting FMRs by streamlining 

HUD’s FMR determination process and giving housing agencies added authority 

to protect families from rent increases stemming from FMR reductions. 

• Rental Assistance Demonstration. AHSSIA would authorize $150 million for a 

5-year Rental Assistance Demonstration (RAD) testing the conversion of public 

housing and Section 8 moderate rehabilitation units to project-based vouchers 

or Section 8 project-based rental assistance, and $50 million for similar conversions of units from the Rent Supplement program or Rental Assistance Program 

to Section 8 project-based rental assistance. 

RAD offers a promising approach to preservation of needed subsidized housing. 

HUD has just issued a final notice to implement a version of RAD approved by the 

2012 HUD appropriations act. The AHSSIA RAD provision’s most important improvement over the existing version of RAD is that it would permit public housing 

units to receive subsidy levels capped under regular Section 8 rules rather than limiting subsidies to the amount the units received through public housing prior to conversion. This would make RAD a more effective and flexible tool, but only if appropriators provided the needed funds—a step they were unwilling to take in the 2012 

act. 

• Economic Security Demonstration. AHSSIA contains a provision not included in 

SEVRA directing HUD to carry out a demonstration to rigorously evaluate options for helping to increase the economic security of housing assistance recipients, including financial incentives, work requirements, and other interventions, 

and authorizes $25 million for this purpose. Such a demonstration could generate important information about the effectiveness of policies to promote economic security. If Congress enacts it, however, it should specify that new policies may remain in place only during the demonstration or until otherwise allowed by Congress, to avoid leaving harmful policies in place indefinitely. 

• Moving-to-Work. The version of AHSSIA passed by a House Financial Services 

Subcommittee in February 2012 contained a harmful provision permitting an 

unlimited expansion of the Moving to Work (MTW) demonstration, which currently exempts 35 housing agencies from nearly all Federal housing laws and 

regulations. This would risk deep cuts to housing assistance over time (due to 

the block grant funding formula used in MTW) and harmful policy changes, 

such as sharp rent increases on vulnerable families or time limits on assistance 

even for working poor families who cannot afford to stay in their homes without 

help. Moreover, the sweeping scale of the expansion would make it impossible 

to address a key shortcoming of the existing MTW demonstration—that it has 

permitted risky policy changes without carefully evaluating them to determine 

their true impact. 15

The April version of AHSSIA also contains a large-scale MTW expansion, but the 

expanded program would be subject to significant limitations. These include prohibitions on waivers of some key tenant protections and requirements for rigorous evaluation of the riskiest policies. If Congress enacts an MTW expansion as part of reform legislation, it is essential that it be subject to the limitations in the April 

AHSSIA bill. 

It should be noted however, that even with these limitations MTW expansion 

would still pose serious risks. Most importantly, the April AHSSIA bill would allow 

large (though capped) shifts of funds from the voucher program to other purposes, 

raising the risk that the expansion would result in many fewer needy families receiving housing assistance than would be assisted under regular program rules. 

Moreover, the goals of MTW, such as testing alternative policies and streamlining 

program administration, can be pursued effectively through other, less risky approaches. Consequently, even the more limited MTW expansion in the April 

AHSSIA bill can be justified only if it is critical to the enactment of comprehensive 

legislation containing most or all of the important reforms discussed earlier in this 

testimony. 

73 

Conclusion 

The core provisions of AHSSIA and SEVRA would build on the voucher program’s 

many strengths through a series of measured, targeted improvements that, taken 

together, would deliver important benefits to housing agencies, private owners, and 

low-income families. Moreover, because several of the bills’ provisions extend beyond 

the voucher program, they also would improve the public housing and project-based 

Section 8 programs. 

It is important that Congress expeditiously enact rental assistance reform legislation with these key provisions. The need for housing assistance is unusually high 

today, with elevated levels of homelessness and poverty and widespread foreclosures. Yet Congress appears unlikely to expand resources for housing assistance 

substantially, and is likely to consider substantial cuts—on top of the sharp reductions enacted in recent years to voucher administrative fees, public housing capital 

grants, and other housing programs. 

At this time, the Nation needs its housing assistance programs to be as efficient 

and effective as possible, and the measures in AHSSIA and SEVRA would take 

major steps toward that goal. The bills’ core provisions have been fully vetted 

through deliberations in the past four congressional sessions, and it is urgent that 

Congress enact them this year so that the large Federal savings they would generate—as well as their many other benefits—can begin to be realized. 

74 


HUD Rental Assistance in Rural and 

Urban Areas 

Fd,ftlll) 1\ :012 

'nil' &denl golVl'fflmcnt's !hl\\' I:Irgcst n11L.,) :\.>Slst,lIlC\' progr.1ms - Sectu.'~ IItIOUll"1S (..l)O!C\' 

ooch~[1;, PublIC" I r!~~illg.~,1(l ~lul!lr~""ly \.'-S~tc,J ",m~ rrm,d~ "y{'l" ,~ mJUi011 ~"'t$ of 

:13!ol>lfU hou.lIIg. 633,1)0(), or I ~ 1"f1."('I1t, of which m localt'll Il\IlS!dc (~ !llttropoh~'fl :1('f"~S . In 

..Jd"Kln tu 110(':«; pmJ;"',m, .<1111111,,,,;,,·,1 h) If,., rkp"nmeflf r,( 1 h''''1J; and l:rl~lIl Dc>e"'P'Ilo:", 

IIL'Dl, the L5.l)qxomnl,H ,if \gn.:ulture'. l{u'1llllllllOlllgSm',c.e (l'!\Wldes fl..1lt.,j ,'-~I~r.tno: In 

2(i~J)j~II"'l$t'IM,IJ,.· 

\CI..~'nlmg p. I Il'D', "".151 rl'l:cm npJrt. I!-I p=ent uf rent ....... \wh ""'u ... r-l-"~t" hWSlng rn:t:tIs 

h~ In nntt.4l tm~ flr $lIllUl1\.'I. willII' 16 rcn--enr IJve In n,j[l-Il"'TTl11"11"J!" Me:\.< ~ \\ nile the number 

of fnlL'~,IJ;·-1l.«lsted Jirord,hle rent..1 "",1'1 .. only~ufiio"m It> ~rye~l~lut I.nt 111 f.,ut d!f;1hle 

fimu ~' thell" dt.<mb\mf~l .\Ct'1S' mcm'f'Ol,tm olnd m'n'rTlf:lrQPoilr.'ln .ueu l! n' d,.se l'!1J!'Onilln n. 

",I..m-r nt'rd. 

14,854 

1,328 

112705 

'." 

:<5 ".'" .315 

13,437 

4 61S 

50,009 

23,1!O1 

3.213 

'.'" "" "'''' "'" 8,474 

13,772 

16,073 

61.441 

32.64tl 

6024 
75 


Public Housing lWts 

••• "". Non-Metro Metro Non-M!uO ...,. 

North Dakota 2;351 4,213 762 2,239 

Nebtll$k3 2.737 8,535 ''''' '86' >1" 3.365 

New fWTJpslire 2,'" 6,167 875 3,'" New jelleY 60,107 49,621 "'" 

N8\JI MIl)1co 3f43 1 .... Uls< "8' 4,312 

1.041 12.024 '" 3,812 

til27 200486 4966 6,641 126,913 

13,718 75,810 113T2 67,637 

'I'" 19.122 5,291 9573 

7451 24,941 2,!iBt 8,720 .,20 613» '''' 8,024 ~,163 

RIIode Iillaod 8,517 16,347 

south C3!oI:na 4,248 19,621 ,,'.3 5.496 15.210 

Sa~th Onkotn "" '.100 003 "40 2,686 

4,32~ 29lJfl3 10.190 1."" 27,600 

13,775 127,479 10)33 1,656 56.204 

5" 9,798 )41 402 "'2 

\llfglnla 4.874 36215 1.369 5,015 JO,9:f.i 

Vermont 2 .. '3,"" 1247 

Wmington "00 " .. '.325 ,,505 )W2 :1188 11,490 

'N!5(onsin 3,990 "''' 1,543 25,459 

""" 1.46S 5.329 '''' 

Notes 

• Th. ~ lilt O\ltl1he. .)( ..... 1> R'«J\'1!!g "" .. I~1tt uoJo, rhe (,0\ ~_;:! l ,,,,,,I UII>I"l<t I""l§tom: -« rht U(I 

,1=1111 h!!jl'lIut. 'bt>P'Irl' !aaItJ ~!!h.",,-I'SpdL 

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""""nc r", rtu' Of 4, «I III ·t.-.ody III~ ~1Og <!,"<l,tI<.<J. 

's.. DougIoI R.tr ",wl 1S..!b.r. Son:!, "1X<alc- "r \'<gIra It.. ,~<tokc.w Fcdcr.l L, .. ·r,,,,,,,nc Ilowmg l'..-.gmm.<· u nitt "" ~ "ud I\.oIj<,- l'nont .... r .. ton...), ~19. bup /1",....· d"'2llf.,i<D!!/""k, 'lmru"'!Sl!''''aI''',!!o')1 

'\!Ill ~foon~ t ........... ,:nll(i<' 8 ~.~ G)Ulfl\l(~"" "f SlJ .. !IIIIU.oI JWubdi!.""" ..:luoJ..rg.!l.~/g p~,!«h) . .,..J on ,>Ihtt 

roolrif .... J,·ou,\IrJ r~..,..," .. -idt A r \ 'n'ur_. 0' 111 'D iUh,1Ilr fi.,.;ludong:;""',., ~ l,.(o~ \LoI'f:<"''''" Rt.u.1 

'''''''0'''' p~'S""" (R.\JI). knl s...wkn",,,~ P"'P""\" o.'l'"rl'''''''. Sot_ 2IJ1I811 <>pm! od,',," .... ..,d r..... .. """,,) 

r",~~"dN~..J""''"'''''''_''IoCt" 1m rift .... I'CI&"¥ lor" .. " 

8!:::u\" '·"n .... LIlI74r "i", ':Jr, 
76 

1 NLIHC. Housing Spotlight: The Shrinking Supply of Affordable Housing. February 2012. 

http://nlihc.org/library/housingspotlight/2-1 2 June 7, 2012. House Financial Services Subcommittee on Insurance, Housing, and Community Opportunity hearing, ‘‘Oversight of Federal Housing Administration’s Multifamily Insurance Programs’’. http://financialservices.house.gov/Calendar/EventSingle.aspx?EventID=297671 3 NLIHC. Housing Spotlight: The Shrinking Supply of Affordable Housing. February 2012. 

http://nlihc.org/library/housingspotlight/2-1 

PREPARED STATEMENT OF LINDA COUCH 

SENIOR VICE PRESIDENT FOR POLICY AND RESEARCH, NATIONAL LOW INCOME

HOUSING COALITION

AUGUST 1, 2012 

On behalf of the National Low Income Housing Coalition (NLIHC), I would like 

to thank Chair Menendez and Ranking Member DeMint for holding this important 

hearing. The Nation’s need for the programs under discussion today is growing. We 

greatly appreciate your leadership on HUD’s rental assistance programs and your 

commitment to the people they are intended to assist. 

The National Low Income Housing Coalition (NLIHC) is dedicated solely to 

achieving socially just public policy that assures people with the lowest incomes in 

the United States have affordable and decent homes. 

Our members include nonprofit housing providers, homeless service providers, fair 

housing organizations, State and local housing coalitions, public housing agencies, 

private developers and property owners, housing researchers, local and State Government agencies, faith-based organizations, residents of public and assisted housing and their organizations, and concerned citizens. NLIHC does not represent any 

sector of the housing industry. Rather, NLIHC works only on behalf of and with low 

income people who need safe, decent, and affordable housing, especially those with 

the most serious housing problems. NLIHC is funded entirely with private donations. 

Need for Affordable Housing Is Growing 

NLIHC analysis of American Community Survey data shows there were 9.8 million extremely low income (ELI) (households with incomes less than 30 percent of 

area median) renter households in 2010 and only 5.5 million units renting at prices 

they could afford, resulting in an absolute gap of 4.3 million units affordable to ELI 

households. In 2009, this gap was 3.9 million units. Because higher income households rent some of the units that ELI households could afford, the gap of affordable 

and available units for ELI households in 2010 was 6.8 million; 1 in 2009, it was 

6.4 million. 

These numbers are equally stark at the State level. In New Jersey, there is a 

shortage of more than 189,000 units affordable and available to ELI households. In 

South Carolina, the shortage of affordable and available units for ELI households 

is more than 79,000. 

HUD’s Office of Multi-Family Housing Programs/Federal Housing Administration 

Deputy Assistant Secretary Marie Head testified in the House in June that increased market demand for new rental housing is directly attributable to the fact 

that ‘‘as many as 3.9 million former homeowners have been displaced by mortgage 

distress and are now in the rental market,’’ and the entrance of ‘‘as many as 4.3 

million new renter households’’ into the rental housing market. 2

One result of this influx is that the percentage of renter households paying more 

than half of their income on rent and utilities increased across all income groups 

between 2009 and 2010, with extremely low income and very low income (VLI) 

(households with incomes less than 50 percent of area median) renters most affected. Seventy-six percent of ELI renters and 36 percent of VLI renters had a severe housing cost burden in 2010, compared with 74 percent and 34 percent, respectively, in 2009. 3 In New Jersey, households with annual incomes below $26,607 are 

considered ELI; in South Carolina, households with incomes below $17,175 are. 

In New Jersey, the public housing program serves more than 40,000 families with 

an average annual income of $15,746, and the voucher program assists almost 

63,000 households, with an average annual income of $15,790. In South Carolina, 

the State’s more than 23,000 rental assistance vouchers serve households with an 

average annual income of $11,000; the average annual income of the State’s 15,000 

public housing households is about $10,400. Without HUD assistance, we can be assured that many of these extremely low income families would be severely cost burVerDate Nov 24 2008 09:17 Apr 26, 2013 Jkt 048080 PO 00000 Frm 00080 Fmt 6621 Sfmt 6621 L:\HEARINGS 2012\08-01 & 12-11 HUD S RENTAL HOUSING ASSISTANCE PROGRAMS, 
77 

4 ‘‘State of Homelessness in America 2012’’. National Alliance To End Homelessness. Washington, DC. http://www.endhomelessness.org/content/article/detail/4361/ 5 Ibid. 

6See, letter and NLIHC press release, ‘‘Advocates Urge U.S. Senate To Act Now on Voucher 

Reform Legislation’’. September 21, 2011. http://nlihc.org/press/releases/9-21-11 

dened or, indeed, would join the ranks of the Nation’s homeless population, which 

totals more than 630,000 on any given night. 4

As the National Alliance to End Homelessness’ annual ‘‘State of Homelessness in 

America 2012’’ pointed out in January of this year, ‘‘Homelessness is a lagging indicator, and the effects of the poor economy on the problem are escalating and are 

expected to continue to do so over the next few years.’’ 5 It is NLIHC’s hope that 

improvements made to HUD’s housing programs by broad authorizing legislation 

will result not only in efficiencies that increase the number of households served, 

but also in greater Congressional support so that homelessness can be prevented 

and ended in the United States. 

NLIHC held a summit of voucher stakeholders in 2005, in response to upheaval 

in the housing choice voucher program instigated in the spring of 2004 by a flawed 

allocation by HUD of otherwise adequate voucher renewal funding. This left many 

agencies with insufficient funds and ultimately caused the loss of more than 100,000 

vouchers nationwide. Sixty-six people attended, including voucher holders and representatives from advocacy groups, public housing agencies and their trade groups, 

affordable housing developers, housing finance agencies, HUD, the Office of Management and Budget, financial institutions and congressional policy and appropriations staff from the House and Senate and both sides of the aisle. 

Many of the recommendations made by those at the voucher summit have been 

included in various iterations of the Section 8 Voucher Reform Act, the Section 8 

Savings Act, and the Affordable Housing and Self-Sufficiency Improvement Act. 

These include recommendations regarding income targeting, rent simplification, 

portability, inspections, project-based vouchers and enhanced vouchers. 

As we did in 2005, we continue to believe there are many reasons for Congress 

to enact broad housing reforms. Since 2005, Congress has worked on various 

versions of the Section 8 Voucher Reform Act, the Section 8 Savings Act, and the 

Affordable Housing and Self-Sufficiency Improvement Act. The HUD programs we 

come together to talk about today are critical to meeting the needs presented by 

these data. The housing choice voucher, project-based Section 8 and public housing 

programs are all deeply income targeted and all provide housing stability even if 

individual household incomes fluctuate with changing circumstances. 

In the fall of 2011, NLIHC worked with other national organizations to coordinate 

a letter, signed by more than 810 local and national organizations, urging the Senate Committee on Banking, Housing, and Urban Affairs to act expeditiously on 

housing reform legislation. ‘‘The savings and efficiencies created by this good Government bill are needed as soon as possible,’’ the letter said. 6

We are encouraged by this hearing and hope legislation can be enacted this year 

that: 

• Improves the programs from the perspective of assisted households 

• Results in savings and efficiencies 

• Stabilizes voucher renewal funding 

Legislation That Improves the Programs From Perspective of Assisted Households 

NLIHC supports several policy changes that would improve the programs: 

• Encourage increased earned income while maintaining Brooke 

Upon increases in earned income, NLIHC supports reforms so that most families 

would not have to recertify their incomes in between annual income certifications. 

This would allow families to hold on to 100 percent of their increased earned income 

until their next annual income certification. PHAs and owners, under various 

versions of the legislation, would base rents on prior year income. Again, this could 

encourage increased earned income by residents. 

Early versions of housing reform legislation would expand the now-narrow Earned 

Income Disregard to all tenants, allowing the first 10 percent of earned income to 

be disregarded for purposes of establishing household rents. Unfortunately, and for 

cost reasons, that provision has not been in recent versions of the housing reform 

bill and the existing, limited Earned Income Disregard for some residents is eliminated. NLIHC supports expanding the Earned Income Disregard. 

Any housing reform legislation should also revise the frequency of income recertifications for families on fixed incomes. NLIHC supports provisions that would reVerDate Nov 24 2008 09:17 Apr 26, 2013 Jkt 048080 PO 00000 Frm 00081 Fmt 6621 Sfmt 6621 L:\HEARINGS 2012\08-01 & 12-11 HUD S RENTAL HOUSING ASSISTANCE PROGRAMS, 
78 

7O’Regan, Katherine O. (NYU Wagner Graduate School and Furman Center) and Keren Horn 

(University of Massachusetts, Boston). What Can We Learn About the Low Income Housing Tax 

Credit Program by Looking at the Tenants? July 1, 2012. http://nlihc.org/sites/default/files/ 

LIHTClTenantlReportl2012.pdf 

quire families on fixed incomes to recertify their incomes once every 3 years, instead 

of annually as is now the case. This could lead to less paperwork for fixed income 

households, and administrative savings for PHAs and owners. 

Critically, these simplifications to the rent-setting process can be enacted without 

jeopardizing the Brooke Amendment, named after former United States Senator Edward Brooke (R-MA). The Brooke Amendment caps tenant rents at a percentage of 

adjusted income, today 30 percent, while continuously connecting each household’s 

rent to its own income. This ensures affordability and housing stability for each 

household. If we cannot rely on every household’s rent being affordable, then there 

is little value in any housing assistance program. 

• Payment standard for people with disabilities 

To reduce administrative tasks as well as improve the effectiveness of the voucher 

program for people with disabilities, NLIHC supports provisions giving PHAs the 

authority to increase the payment standard to 120 percent without having to seek 

HUD approval as a reasonable accommodation to persons with disabilities. 

• Expanding affordable rental stock by improving project-basing of vouchers 

NLIHC supports provisions that have been in most versions of housing reform legislation that would improve how vouchers could be project-based into properties, allowing otherwise unaffordable units to meet the affordable housing needs of the lowest income households. 

There are several provisions to improve the project-basing of vouchers, all of 

which NLIHC supports including in any housing reform bill: 

1. Changing the limitation on vouchers that can be project-based from 20 percent 

of an agency’s voucher funding to 20 percent of an agency’s authorized vouchers. 

2. Allowing a PHA to use an additional 5 percent of authorized vouchers to serve 

persons with disabilities, elderly households or homeless populations or be 

used in areas where vouchers are hard to use. 

3. Increasing the number of units a PHA can provide with project-based voucher 

assistance in smaller properties. 

4. Increasing the maximum contract term for project-based vouchers from 15 to 

20 years. 

Improvement to the project-basing of vouchers can help programs like the Low Income Housing Tax Credit (LIHTC) serve more extremely low income households in 

an affordable way. Without additional subsidies, often in the form of a Housing 

Choice Voucher, Low Income Housing Tax Credit units are simply not affordable to 

extremely poor households. Vouchers, and project-based vouchers, ensure stable 

housing as a family’s income fluctuates. Doubling up Federal subsidies in LIHTC 

units by adding a voucher makes these units affordable for the households with the 

greatest housing needs in the United States. Without additional subsidy, the Nation’s largest subsidized affordable housing program is simply not affordable or viable for ELI households. 

Recent research 7 from data collected per the Housing and Economic Recovery Act 

of 2008 reveals that there are indeed ELI households served by the LIHTC program, 

about 43 percent of units assisting such households. 

It appears, however, based on data provided by the same report, that without 

rental assistance these extremely poor households are paying more than half their 

incomes for their housing costs, thus meeting HUD’s definition of households with 

‘‘severe housing cost burden.’’ The data presented by the report show that 31 percent of ELI renters in LIHTC units receive no rental assistance, Housing Choice 

Vouchers or otherwise. The report also presents data that fully 30.6 percent of ELI 

households in LIHTC units are severely cost burdened, paying more than half of 

their income for rent in these units. Voucher assistance attached to these units 

through the project-basing of vouchers, or provided to these tenants directly with 

housing choice vouchers, brings housing affordability and stability to these households. 

• Other provisions to improve the programs from the perspective of assisted 

households 

79 

NLIHC also supports including provisions from past housing reform bills that 

would direct HUD to develop new portability regulations that minimize billing and 

administrative barriers to portability, provide public housing agencies and HUD 

with tools to address excessive rent burdens as well as concentrations of vouchers 

in higher-poverty areas by adjusting payment standards, and allow vouchers to pay 

for home payment (since the Quality Housing and Work Responsibility Act, vouchers only pay for rental of land). All of these provisions will improve people’s access 

to their communities of choice. 

Legislation That Results in Savings and Efficiencies 

• Overall savings 

Any version of housing reform legislation saves Federal resources, ranging from 

around $700 million to $1 billion over 5 years. These are tremendous savings, the 

vast majority of which are uncontroversial. 

• Definition for deep income targeting 

A major source savings from any housing reform bill would be a change to how 

targeting of assistance to extremely low income households could be carried out. 

Today, these large HUD programs must target a certain percent of new housing assistance each year to extremely low income households. NLIHC supports reforms 

that would expand this deep income targeting category to be the greater of households with incomes below 30 percent of area median income (extremely low income) 

or the Federal poverty line. This will help target assistance to very poor households 

in rural areas, where incomes overall are low. 

• Rent simplifications 

In addition to the rent simplification provision discussed above, requiring fixed income households to recertify incomes every 3 years instead of annually, housing reform legislation can do much to simplify the rent setting process. NLIHC also supports the ability of PHAs and owners to rely on other Federal means-tested assistance programs, including the Supplemental Nutrition Assistance Program, to verify 

tenant income. 

Simplifying the deduction of medical and related expenses has long been a goal 

of housing reform legislation. Raising the percent of income that must be exceeded 

before unreimbursed medical or related expenses are deducted from income is one 

way that versions of housing reform legislation have simplified the complicated 

rent-setting process. As the House and Senate have always supported, any such increase in the threshold for deducting expenses must be coupled with an increase in 

the standard deduction for elderly families and families with disabilities. Hardship 

provisions to protect households with outlier medical expenses are also good policy. 

• Create efficiencies; do not weaken accountability 

NLIHC is interested in balancing efforts to create efficiencies with retaining the 

programs’ accountability, both to local communities and to Congress and HUD. 

While efficiencies can bring savings through reduced program costs, we urge caution 

when considering exempting agencies from standards HUD and Congress use today 

to measure public housing agency performance. Even exempting the smallest agencies, as some housing authority groups support, from many Section 8 Management 

Assessment Program indicators would remove accountability on key indicators like 

accuracy of payment standard calculations, use of all available vouchers and expansion of housing choice from agencies that administer a tenth of the Nation’s vouchers. Congress’s understanding of how the voucher program, under such circumstances, was actually meeting the Nation’s housing needs would be incomplete 

if such reforms were enacted. NLIHC believes that such changes would put rental 

assistance programs at risk of reduced funding in the future as Congress’s understanding of their use and impact fade. 

Legislation That Stabilizes Voucher Renewal Funding 

• Voucher Renewal Funding 

The need for clear direction to HUD on the allocation of voucher renewal funding 

was a primary reason for the development of this legislation several years ago. The 

viability and credibility of the voucher program is rooted in a stable, sufficient and 

reliable voucher renewal funding policy. NLIHC supports authorizing language 

whereby the annual appropriation of each agency administering vouchers is based 

on actual leasing and cost data from the last calendar year, with various adjustments, including for tenant-protection, project-based and ported vouchers. NLIHC 

also supports policies that would support agencies’ over-leasing of vouchers. 

80 

8 NLIHC. Press release: ‘‘President’s Budget Request Creates Grim Outlook for Low Income 

Housing’’, February 13, 2012. http://nlihc.org/press/releases/2-13-12 9 NLIHC. Affordable Housing Dilemma: the Preservation vs. Mobility Debate. May 2012. 

http://nlihc.org/library/other/periodic/dilemma 

NLIHC supports offset and reallocation policies that will bring additional stability 

to the program. Offset policies in previous versions of housing reform legislation, 

supported by NLIHC, would allow HUD to offset a PHA’s voucher allocation by the 

amount its reserves exceeded 6 percent. The HUD Secretary would then be authorized to use these offsets for a variety of purposes, including for increased costs due 

to portability, significant increases in voucher renewal costs resulting from unforeseen circumstances and reallocating to PHAs to avoid or reduce any pro-rations of 

renewal funding. 

NLIHC also supports an advance mechanism to PHAs that could act as a safeguard for agencies that experience a temporary shortfall in funds. NLIHC supports 

provisions that allow a PHA to request, during the last quarter of the calendar year, 

up to 2 percent of its allocation to pay for additional voucher costs, including costs 

related to temporary over leasing. NLIHC believes that this will give some PHAs 

the assurance they need to increase their voucher utilization rates. These advances 

would have to be repaid and could not occur in 2 consecutive years. 

Minimum Rents 

NLIHC does not believe that increasing minimum rents is needed to create a robust housing reform bill. The latest House draft bill is an improvement over earlier 

versions, especially because it would greatly improve hardship exemptions from 

minimum rents for households and because it offers housing agencies and owners 

the ability to have minimum rents lower than the bill’s $69.45 a month for good 

cause. 

The House’s latest proposal impacts households with incomes of less than $2,800 

a year. While it may seem hard to imagine that there are households with incomes 

so low, the reality is that these households exist and the programs keeping them 

off the street, out of the back seats of cars at night and out of shelters, are HUD’s 

voucher, public housing and project-based Section 8 programs. NLIHC supports the 

House draft bill’s improvements to hardship exemptions. We continue to oppose any 

increase in minimum rents, which by definition only impact the lowest income 

households. 

NLIHC was shocked and disappointed that the Administration requested increased minimum rents in its FY13 budget request, which it said could generate 

$150 million in revenue. ‘‘The Budget Control Act created spending limits that are 

so unworkable that the Federal Government is reduced to picking the pockets of the 

poorest of the poor. It is Scrooge-like,’’ NLIHC’s President and CEO Sheila Crowley 

said in a press release on February 13. 8

Bigger Reforms in the Future 

NLIHC also supports additional policy proposals to improve the voucher program. 

We are very pleased that HUD is moving forward with its Small Area Fair Market 

Rent (SAFMR) demonstration. The SAFMR demonstration project will determine 

FMRs at the ZIP code level, so payment standards will more closely reflect local 

market conditions and rents by neighborhood. As noted in a 2012 NLIHC paper, Affordable Housing Dilemma: the Preservation vs. Mobility Debate, ‘‘Going to small 

area FMRs would cause ‘such a redistribution of poor people over time in metro 

areas, because there’s so many rental units that would be accessible all of a sudden 

that aren’t accessible now.’ ’’ 9 HUD will conduct an evaluation of the demonstration 

program to determine if using SAFMRs will increase neighborhood choice for program participants and increase program efficiency overall. NLIHC is eager to see 

HUD’s evaluation of the SAFMR demonstration. We are confident that the results 

will show that the use of SAFMRs should be adopted nationwide. 

Another potential bright spot in the Nation’s ability to simplify the administration 

of vouchers is to encourage PHAs to join forces and regionalize voucher administration. Regionalizing voucher administration, as has been done in several communities 

across the country, will result in greater housing choice for tenants and greater program efficiencies for administrators. Voucher holders in the metropolitan Washington, DC, area, for example, are restricted from moving freely within our housing 

market because of PHA geographic boundaries. What makes the most sense is for 

the jurisdiction of the voucher administrator to match the jurisdiction of the overall 

housing market. The voucher program does not naturally do that today, but it 

should in the future. 

81 

10Poverty & Race Research Action Council. Keeping the Promise: Preserving and Enhancing 

Housing Mobility in the Section 8 Housing Choice Voucher Program. March 2011. http:// 

prrac.org/pdf/AppendixB-Feb2010.pdf 

NLIHC also supports creating Federal source of income laws, which would basically prohibit a landlord or property manager from denying housing to a prospective 

tenant because of precisely how they would pay their rents, or the source of their 

income. According to the Poverty & Race Research Action Council (PRRAC), 13 

States and dozens of cities have some version of source of income protections. 10 Federal source of income protections could expand the properties and communities 

where voucher holders can chose to live. According to an analysis of research on discrimination in the voucher program in this same report, PRRAC notes that discrimination against voucher holders contributes to peoples’ inability to use rental assistance vouchers in their neighborhoods of choice. 

A real breakthrough would be to make assistance from the housing choice voucher 

program an entitlement to those households eligible for it, or at least for certain 

populations. Today, the only housing entitlement programs are for homeowners, and 

the vast majority of those resources assist high income households. Moving the 

voucher program into the world of entitlements, at least for certain populations, 

would demonstrate real commitment by Congress that everyone has a right to safe, 

decent, and affordable housing. 

Moving to Work 

No discussion of housing reform legislation would be complete without consideration of the Moving to Work (MTW) demonstration program. The demonstration, authorized in 1996, has been an exercise in broad regulatory and statutory flexibility 

for a few dozen housing agencies and in growing frustration for groups like NLIHC, 

which seek to advance housing solutions for the lowest income people. The frustration comes from the inability of NLIHC, or any other entity, to know what the impacts of these broad statutory and regulatory flexibilities have been on the current 

and future low income residents of these housing authorities, and on the physical 

and financial health of these housing authorities. Yet, housing agencies continue to 

seek participation in the MTW program, hopeful that participation will bring salvation from years of chronic underfunding in the public housing operating and capital 

funds and voucher administrative fees. 

NLIHC joined several national organizations and HUD early this year to see 

whether a compromise could be reached on MTW, a compromise acceptable enough 

to all that broader housing reform legislation could move forward. This ‘‘stakeholder’’ group did eventually turn months of hard decisions and compromises into 

an agreement on MTW expansion, which was included in the April 13 version of 

the House’s draft Affordable Housing and Self Sufficiency Improvement Act. 

The stakeholder agreement on MTW would allow up to 500,000 units administered by high-capacity PHAs to be included in a ‘‘basic’’ MTW program. Units in 

basic MTW would have the flexibility to streamline administrative procedures. Up 

to 25 agencies could also participate in an ‘‘enhanced’’ MTW program, which would 

have the ability to implement harmful policies, like rent reform, work requirements 

and time limits only if doing so is part of rigorous evaluation protocols. For all, income targeting, resident rights and housing affordability would be protected to a significantly greater extent than in the current demonstration sites. 

While NLIHC has agreed to this carefully crafted version of MTW expansion, history shows that MTW expansion has resulted in the stalling of housing reform legislation for years. NLIHC would strongly support moving forward with voucher reform legislation without an MTW title. MTW legislation could be considered separately, while the significant savings and efficiencies of a broader housing reform bill 

could be taken advantage of now. 

Some versions of housing reform legislation, including the most recent House 

draft, have included other demonstrations as well (i.e., a rent policy demonstration 

and an economic security demonstration). HUD is already conducting a rent policy 

demonstration and should not need additional authority to complete this work. The 

goals of the economic security demonstration, and its cost of $25 million, could be 

brought into whatever form the MTW demonstration eventually takes, taking on all 

the protections for current and future residents, evaluation components, and size 

and duration limitations of MTW that would be necessary to test hypotheses while 

protecting people and assets. NLIHC opposes these additional, standalone demonstrations. 

82 

National Housing Trust Fund 

While enactment of housing reform legislation would generate hundreds of millions in savings in the near future, NLIHC also encourages Members of this Subcommittee to support capitalization of a National Housing Trust Fund, which Congress authorized in 2008. The National Housing Trust Fund, coupled with the stabilization of HUD’s rental assistance programs by housing reform legislation, could 

end homelessness in the United States. Each State has a shortage of affordable and 

available units for ELI households. Housing reform legislation could stabilize existing programs and give Congress the assurance that these highly efficient programs 

deserve more Federal resources. But, we also need to dramatically increase the actual number of units affordable to ELI households. The National Housing Trust 

Fund is the mechanism to accomplish this. NLIHC looks forward to working with 

the Senate on ways to capitalize the NHTF. 

Thank you for considering our testimony. 

83 

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87 

RESPONSES TO WRITTEN QUESTIONS OF SENATOR SCHUMER 

FROM KEITH KINARD 

Q.1. Improvements to the Project-Base Voucher Program: 

The Project-Based Voucher program is a unique tool that a PHA 

can use to help create or redevelop affordable housing. A PHA that 

operates a PBV program can use it to facilitate the redevelopment 

of existing assisted housing or use to create mixed-income housing 

in areas that are being targeted for community redevelopment. The 

Affordable Housing and Self Sufficiency Improvement Act, currently pending in the House Financial Services Committee makes 

changes to the program that would enable a PHA to use the PBV 

program to target vulnerable populations, provide 100 percent assistance to small properties and provide additional assistance to 

properties located in high-cost markets. 

Do you support the changes the Affordable Housing and Self Sufficiency Act makes the project-based voucher program? How will 

these changes help you better serve low-income families in your 

community? 

A.1. Yes, CLPHA supports the changes that the Affordable Housing 

and Self Sufficiency Act (AHSSIA) would make to the project-based 

voucher program. The project-based voucher program is an important tool in the redevelopment and the rehabilitation of our Nation’s public housing stock and the changes that AHHSIA makes 

to the program will allow more housing authorities to utilize this 

tool. Changing the percentage limitation so that it is based on authorized units, rather than funding levels, makes that limitation 

less of a moving target because it will be based on a more predictable measure and will facilitate housing authorities’ maximizing 

project-basing authority. Raising the percentage limitation by 5 

percent for projects that house families with veterans or that provide supportive housing to persons with disabilities or elderly persons will better enable and encourage housing authorities to target 

those vulnerable populations in their plans for project-basing. Increasing limits on both the percentage limitation and income mixing requirements in areas where vouchers are difficult to use will 

enable housing authorities to respond to their local market conditions more easily. Allowing site-based waiting lists will streamline 

administrative procedures considerably. AHHSIA’s changes to the 

project-based voucher program will increase the supply of deeply 

subsidized hard units in communities that truly need them and 

make more affordable housing units available to vulnerable populations. 

Another change to the project-based voucher program that 

CLPHA believes should be included in AHSSIA would be to allow 

housing authorities to attach project-based vouchers to housing authority-owned structures without following a competitive process. 

This would remove a step from the project-basing process that consumes a great deal of time without adding value. Additionally, 

CLPHA notes that in a previous iteration of the Section 8 reform 

bill, the project-based voucher percentage limitation was raised to 

25 percent across the board, with an additional 5 percent targeted 

to vulnerable households on top of that raised threshold. CLPHA 

would prefer that any subsequent Section 8 reform bill return to 

that arrangement. 

88 

Newark has already benefited from the project-based voucher 

program, and any changes enacted that make the project-based 

voucher program more accessible to housing authorities will benefit 

low-income communities. Newark currently supports a 200-unit 

building for the elderly and individuals with disabilities through 

the project-based voucher program; the development receives 100 

percent of its assistance through project-based vouchers. Without 

the funding flexibility that the project-based voucher program provides, Newark would not have been able to address the extensive 

capital needs of the building or to upgrade the general amenities 

available to residents. The development is now thriving and is a 

place that makes residents and Newark proud. Despite this success, Newark still hits administrative roadblocks in the current 

project-based voucher program when trying to structure redevelopment deals. For the past 4 years, Newark has been in the process 

of converting a 220-unit building for the elderly and individuals 

with disabilities to a Section Eight Project Based facility. We are 

still only 70 percent of the way through the conversion due to the 

administrative procedures of the program, in which Newark was 

required to competitively procure and ultimately award the projectbased vouchers to ourselves. The provisions in AHHSIA relating to 

the project-based voucher program will not only bring welcome administrative relief, but the revitalization of public housing for the 

benefit of low-income communities. 

Q.2. Exempting public housing redevelopment from counting 

against a PHA’s project-base voucher funding limitation: 

The PBV program limits a PHA from project-basing more than 

20 percent of its voucher funding. Many PHAs around the country 

have been using the PBV program as a tool to redevelop and rehabilitate its public housing stock. Recently, HUD has embraced this 

principle by allowing a PHA to convert its public housing assistance to a 15 year PBV contract through the Rental Assistance 

Demonstration program. Unfortunately, for many PHA’s unable to 

utilize the RAD program, the 20 percent limitation may still be a 

barrier for them to redevelop their own public housing stock. A 

simple solution would be to exempt public housing revitalization 

that a PHA undertakes from the 20 percent voucher-funding cap. 

This would then allow a PHA to continue to reposition its public 

housing stock and also continue to use the program in a manner 

that best serves the low-income households in the surrounding 

community. 

Would you support a change to the project-base voucher program 

that would provide an exception to the 20 percent voucher funds 

limitation for PHAs that use the PBVs to redevelop its own public 

housing stock? Are there are other limitations or changes you 

would make to the RAD program that would make it easier for a 

PHA to redevelop public housing in a manner that protects the 

Federal investment and provides safe, decent housing for low-income households? 

A.2. Yes, CLPHA supports a change to the project-base voucher 

program that would provide an exception to the 20 percent voucher 

limitation for all housing authorities that use the project-based 

vouchers to redevelop its own public housing stock. Project-based 

89 

vouchers have become an essential tool for housing authorities’ efforts to meet their local community needs, especially for vulnerable 

populations that require supportive services. The lifting of the 20 

percent cap will allow housing authorities—particularly those unable to participate in the Rental Demonstration Program (RAD)— 

the ability to preserve hard units for extremely vulnerable populations who might not be able to find a place to live in the private 

rental market. 

Housing authorities that are able to participate in the RAD program will be better able to serve their communities because RAD 

incorporates a 20 percent cap exception and increases the percentage of vouchers that may be project-based in a single project. However, it would be easier for housing authorities to redevelop public 

housing under RAD if a greater percentage of vouchers could be 

project-based in a single project. This change would allow housing 

authorities to leverage their project-based vouchers more effectively 

in redevelopment deals, which would preserve and redevelop more 

units of public housing, and thus ultimately benefit low-income 

households that may not otherwise have access to affordable housing that is both safe and decent. 

RESPONSES TO WRITTEN QUESTIONS OF SENATOR SCHUMER 

FROM DIANNE HOVDESTAD 

Q.1. Improvements to the Project-Base Voucher Program: 

The Project-Based Voucher program is a unique tool that a PHA 

can use to help create or redevelop affordable housing. A PHA that 

operates a PBV program can use it to facilitate the redevelopment 

of existing assisted housing or use to create mixed-income housing 

in areas that are being targeted for community redevelopment. The 

Affordable Housing and Self Sufficiency Improvement Act, currently pending in the House Financial Services, makes changes to 

the program that would enable a PHA to use the PBV populations, 

provide 100 percent assistance to small properties and provide additional assistance to properties located in high-cost markets. 

Do you support the changes the Affordable Housing and Self-Sufficiency Act makes to the project-based voucher program? How will 

these changes help you better serve low-income families in your 

community? 

A.1. Yes, we support the changes the ‘‘Affordable Housing and SelfSufficiency Improvement Act’’ (AHSSIA) makes to the project-based 

voucher program. Listed below is a summary of our position on the 

PBV provisions in the current draft of AHSSIA, as well as additional PBV legislative reforms we support in the December 1, 2010, 

version of the ‘‘Section Eight Voucher Reform Act’’ (SEVRA) as well 

as regulatory reforms stemming from enactment of the ‘‘Housing 

and Economic Recovery Act of 2008’’ (HERA). 

The Sioux Falls Housing & Redevelopment Commission (SFHRC) 

has not, yet, exercised the option of project-basing a portion of its 

Section 8 Housing Choice Vouchers. The decision not to projectbase Section 8 Vouchers is based several factors: First, SFHRC’s 

waiting list is long—approximately 3.5 years from the time an application is received in SFHRC’s office until funding is available 

under the Voucher program with currently over 3,700 households 

90 

on its waiting list. Most applicants want the option of locating a 

dwelling unit that meets their unique circumstances. The majority 

of voucher holders in Sioux Falls have been successful in locating 

units that meet their needs and HUD’s criteria for approving a 

dwelling unit to be placed under a Section 8 Housing Assistance 

Payments Contract. It hasn’t been necessary for SFHRC to projectbase its vouchers in order to for a voucher holder to utilize their 

voucher. 

Also, since SFHRC’s waiting list is so long and most vouchers are 

utilized in a timely manner SFHRC cannot justify taking the 

vouchers ‘‘off-line’’ and holding them through turnover/attrition 

until a project was ready to be occupied. This would be denying 

rental assistance to a family that desperately needs it. While 

HUD’s voucher HAP renewal formula does account for vouchers 

committed to a PBV development under an ‘‘Agreement to Enter 

Into a Housing Assistance Payments Contract’’, the Department’s 

existing Section Eight Management Assessment Program (SEMAP) 

currently does not take this into account. As a result, Public Housing Authorities (PHA) that engage in the PBV program that have 

to take tenant-based vouchers ‘‘off-line’’ are penalized in their 

SEMAP scores. 

Second, the unpredictability of annul housing assistance dollars 

makes it difficult to determine the number of vouchers that can be 

project-based. Currently, PHAs are allowed to project-base up to 20 

percent of its tenant-based funding. It is difficult to strategically 

plan for project-basing vouchers when the pro-ration and the formula for determining renewal housing assistance payments dollars 

changes each year, depending on the language in the appropriations bill. In addition, the timeliness of HUD’s notices of annual 

budget authority makes planning extremely challenging. For example, for calendar year 2008 SFHRC was not notified of its annual 

budget authority until March 14, 2008. The pro-ration was 101.453 

percent; however, the formula included an offset for both Useable 

and Unusable Net Restricted Assets (NRA) which decreased available funding. 

In 2009 SFHRC received notice of its annual budget authority for 

that calendar year on May 5, 2009. The pro-ration was .991 percent, again the formula included offsets of Usable and Unusable 

NRA. 

On February 12, 2010, SFHRC was notified of its annual budget 

authority for calendar year 2010. The pro-ration was .995 percent, 

with no offset. 

For calendar year 2011 SFHRC received notice of its annual 

budget authority on June 14, 2011. The pro-ration was 98.81 percent, with no offset. For the first time HUD included an allowance 

for Family Self-Sufficiency escrow deposits in the formula used for 

calculating housing assistance payments renewal dollars, which increased the dollars for housing assistance payments. Regrettably, 

this is no longer HUD’s practice. 

On March 1, 2012, SFHRC was notified of its annual budget authority for calendar year 2012. The pro-ration was .996 and an offset was included in the formula. 

Although the 2.64 percent difference in pro-ration during these 

5 years doesn’t, on its face, appear to be much, it does impact the 

91 

number of households that can be served and, consequently if there 

would be monies available for the project-based vouchers. It is difficult for SFHRC to estimate the amount of annual renewal dollars 

it will receive as some years there are offsets, some years not. 

AHSSIA: Percentage of PAH’s ACC Units for Project-Basing Vouchers 

Modifying existing laws, as proposed in AHSSIA, so that the 

project-based voucher program limitation is based on authorized 

units, instead of tenant-based funding levels, will be much simpler 

for PHAs and HUD to determine and track. 

AHSSIA: Percent of Units That Can Have Project-Based Assistance 

in a PHA’s Voucher Portfolio 

AHSSIA modifies the current limitation on project-basing up to 

25 percent of the units in a project to the greater of 25 percent of 

the units in a project or 25 units. In areas where vouchers are difficult to use; in census tracts where the poverty rate is 20 percent 

or less; to serve individuals and families that fall under the McKinney homeless definition; that house families with veterans or provide supportive housing to persons with disabilities AHSSIA would 

allow the PHA to project-base 25 units or 40 percent of the units 

in the project. Current regulations require a cumbersome process 

to determine which project should receive project-based vouchers. 

Multifamily projects in Sioux Falls tend be 50 units or less. Under 

existing law, in projects with 50 units, the maximum number of 

vouchers that could be project-based is 12. The amount of work it 

would take to project-base the 12 vouchers is not cost effective. If 

the limitation is increased to greater of 25 percent or 25 units, or 

40 percent of baseline units in areas described above it may become 

cost effective to go through the process for project-basing vouchers 

in certain instances. 

Previous versions of this bill defined areas where tenant-based 

vouchers are difficult to use under HUD’s existing definition of 

‘‘success rate payment standard’’, as PHAs that: (1) established its 

payment standards at 110 percent of the 40th percentile FMR for 

a period of at least 6 months; and (2) established a policy of granting automatic extensions of voucher terms to at least 90 days; but 

(3) notwithstanding these actions, the PHA still has less than 75 

percent voucher holder success rate in finding and leasing units. 

This definition of a tight housing market, where tenant-based 

vouchers are difficult to use, already has existing regulations and 

implementation for PBV program stakeholders. Creating an openended definition subject to formulation by HUD is unnecessary and 

given the Department’s slow track record for implementing regulations would be imprudent. We recommend restoration of the above 

definition of units located in areas where tenant-based vouchers 

are difficult to use. 

We also recommend exempting Public Housing assisted households in a development that is converted to Section 8 Project-based 

Voucher assistance from the percentage of their voucher portfolio 

that they can project-base. In addition, we recommend that PHAs 

with existing PBV contracts from conversions of Public Housing are 

‘‘grandfathered.’’ 

92 

Increasing the number of project-based vouchers would benefit 

the pro forma used to determine if a project is financially feasible. 

It may mean the difference between a project going forward or not. 

AHSSIA: Income-Mixing Requirement 

The simplification of PBV program income mixing requirements 

in AHSSIA for project-based developments by allowing PHAs to attach 100 percent of the dwelling units that serve elderly populations, persons that require supportive services and for projects 

that have 25 units or less would make the program easier to administer. 

Downward HAP Pro-rations 

Under AHSSIA, an initial Housing Assistance Payments Contract between a PHA and the owner of a project may be up to 20 

years (compared with 15 years under current law), subject to availability of sufficient appropriated funds for the purpose of renewing 

expiring PBV contracts for assistance payments, as provided in appropriation Acts and in the PHAs’ Annual Contributions Contract 

(ACC) with HUD. In the event of insufficient appropriated HAP 

funds, payments due under PBV contracts must take priority if 

other cost-saving measures that do not require the termination of 

an existing contract are available to the PHA. Currently, if PHAs’ 

receive downward pro-rations in HAP funds for their tenant-based 

voucher programs, one of the measures available to PHAs to help 

prevent them from having to terminate HAP Contracts and Lease 

Agreements on behalf of existing voucher-assisted households, is to 

lower their voucher payment standards for newly admitted households upon turnover and for households relocating from one unit to 

another with the benefit of voucher assistance. In those instances, 

participants in the tenant-based voucher program pay between 30– 

40 percent of their income towards rent and utilities. Even though 

the PVB program is a subset of the tenant-based voucher program, 

all PBV-assisted households must pay no more than 30 percent of 

their income towards rent and utilities. In other words, when there 

is a downward pro-ration in HAP, tenant-based voucher households 

described above, bear the full brunt of downward pro-rations. 

We understand and appreciate how important it is that PBV 

Contracts receive 100 percent HAP pro-rations, even if the level of 

HAP appropriated funds results in a downward pro-ration below 

100 percent. However, PHAs that utilize a greater percentage of 

their portfolios to PBV assistance will be disproportionately 

harmed in their tenant-based voucher programs as a result of this 

provision in AHSSIA. In addition to the language in the bill, 

NAHRO recommends that PHAs also be provided the authority to 

help make up for downward pro-rations in HAP funds overall, to 

also opt to raise PBV-assisted households Total Tenant Payment 

(TIP) from 30 percent of their monthly adjusted income to between 

30–40 percent of their monthly adjusted income like the tenantbased voucher program. Clearly this is a measure that would only 

be implemented under downward pro-rated HAP funds, as a way 

for all PHAs’ program participants to share the burden of such action. Absent this change, PHAs that may have considered utilizing 

93 

and/or increasing the percentage of their units under the PBV program would face significant financial disincentives in doing so. 

Additional PBV Program Legislative Reforms 

Listed below is a summary of our position on additional PBV legislative reforms we supported in the December 1, 2010, version of 

the Section Eight Voucher Reform Act (SEVRA). 

Site-Based Waiting Lists 

A provision to permit owner-managed, site-based waiting lists, 

subject to PHA oversight and responsibility, and further subject to 

the protection of tenants displaced by rehabilitation. 

Absolute Preference To Prevent Displacement of Existing Eligible 

Residents 

Any family who resides in a dwelling unit proposed to be assisted 

under the PBV program or in a unit to be replaced by a proposed 

unit to be assisted under the program, is required to be given an 

absolute preference for selection for placement in the proposed 

unit, if the family is otherwise eligible for assistance. 

Vouchers Project-Based in PHA Owned Public Housing Properties 

A provision to permit PHAs to attach project-based vouchers to 

a PHA-owned Public Housing project or site without undergoing a 

competitive process. However, PHAs would have to reflect the 

project-based initiative in their ‘‘PHA Plan’’ and the units could not 

receive Public Housing funding. This process would not change eligibility rules under which PHA can project base their own units. 

PHAs would be responsible for any expenses such as Housing Quality Standards (HQS) inspections and rent reasonableness determinations. 

HAP Contract Term 

A provision that would allow the housing assistance payments 

contract between the owner of the project and the PHA to be 20 

years. 

Lease and Tenancy Provisions 

A provision clarifying that lease and tenancy provision pertaining to Section 8 vouchers shall apply to project-basing of vouchers, except for requirements concerning the minimum lease term. 

Enhanced Vouchers 

A provision allowing enhanced vouchers at mortgage maturity for 

properties for enhanced vouchers on prepayment. 

Transfer of Vouchers and Budget Authority 

A provision to allow PHAs to transfer a portion of its vouchers 

and corresponding budget authority to other PHAs to be used to 

provide project-based assistance. The bill states that ‘‘HUD shall 

encourage such agreements and promptly execute the necessary 

and contract modifications. 

94 

Rents in Units Assisted by Housing Trust Fund 

A provision to allow lower rents for vouchers in units assisted by 

a Housing Trust Fund, but only with the mutual agreement of the 

PHA and owner. 

Additional PBV Program Regulatory Reforms 

Attached for your review and consideration please find NAHRO’s 

comments, on behalf of its members, regarding HUD’s proposed 

rule titled: ‘‘The Housing and Economic Recovery Act of 2008 

(HERA): Changes to the Section 8 Project-Based Voucher Programs’’ (Docket No. FR-5242P-01). 

Conclusion 

Mr. Chairman, as this Subcommittee seeks to advance a bill that 

not only makes sense substantively but politically, we urge you to 

consider and ultimately adopt a bill that hews closely to the December 1, 2010, version of SEVRA and reflects some of the more 

thoughtful and constructive provisions in AHSSI that we identified 

today. We see no reason, given the measure of support that the December 1, 2010, version of SEVRA had and the AHSSIA bill for the 

most part now has, to either radically depart from language contained in these constructive approaches to reform—or worse to 

start from scratch. The time for discussion has passed; the time to 

act is now! With specific respect to AHSSIA, we are very pleased 

to see that your House colleagues made significant progress on a 

number of issues important to NAHRO, including to the HQS section, and also retained important language regarding the establishment of administrative fee rates by Congress. Certainly there is 

more that this Subcommittee can do to improve both bills as we 

have noted but, after almost 10 long years of fits and starts, there 

is no reason to undermine largely viable products that have many 

if not most program stakeholders on board. 

On behalf of my colleagues at NAHRO, thank you again for the 

opportunity to come before you and express our opinions regarding 

this vitally important legislation. We look forward to working with 

you. 

95 


July 16,20J2 

National AnodatioD of Housing and Redevelopment Offjcial~ 

6l{1 £~..., S!If'Cl NW, W,"b:r,&tttll.IC 10\101-3730 

(102)289.3500 Toll Pm: I (Sm ~'I..I.7ti F:u.(2O.1)2S'9-8181 

Rcgulalinrol Divisillrl, Offict ofGenml Counsel 

Deparlmel1t ofHousill£ and Urban Df.'VeJopmen! 

4S I 7th Sireet SW., Room J0276 

Washington, DC 204J 0-050(1 

Re: The HouMg IUld Ecunomic Reo.:uI'tt'), Act of lOOS (HERA): Chan,ges to the S«tion S 

Tl'11anl-Based Voucl!cr and Section 8 l'roj«l-B~sed Voucher Programs [DodCl ~o. 

FR- S242- P-OI [ 

To Wbom It May Conc<'rn: 

We welcome th~ opponunity 10 comment on HUO', proposed rule reglU'diJlg Section 8 

Ten:lIlI·Bascd Voucberand Section 8 Project-Based Vou~her programs rule, largely stemmillg 

from the cnactmem (If til<: "Housmg lIJId Economic Recover)' Act of 2008" (HERA). Except: 

wbere noted in our l'O!llIlICl1S, NNIRO COOl"Urs with IIVO's regulatory jrnplemenlnti(ln (If 

Section 8 project·based find tenant·b3.soo program proVisions enaCted in HERoI\.. 

NAHRO rr:preselllS more thUD 3,100 agendes d over 20,000 inrliviJual mem~rs &nd 

as~ociatCli, and i~ the oldl;'S[ and largest 3>sociation serving housing ~nd community 

del'Clopment ag.eocies fur the pro~Jsion offldc<Juate ~nd affordable bqusioll am! suong, \l1.b l~ 

wmmuniti\':i for all Amcri=-partlculJl'lythose with 1011'- ilhd modcral~in~OhJcs. OUf 

mt:rnbcrsadminister HUD progroms sudl ilS Publi.: Housing, Sec1ion 8 Housing (:b(Ii(e 

Vouchers, COBG arn.l I-lOME. 

RUjODablc RCQU for IJUTC-ASlimd linits Withoul S~clioo 8 Assi$tQnce 

I §9112.5IJ7(c)(2)1 

HUI)"s pro~ rule, 24 CtR §982,507(c) slales that if a rem r~qucslCil by a property owner 

e,~cced:s th~ Low-Income Housing Ta'l: CI'I.'dit (LlHTC) rfnt for hoo..<eholds not recciving 

Section 8lenant·bastd or proj«t·l>rucd voucher assistRnce, than I PHA is m:juin:J to conduct 

a rent reasonableness detcnninatiOIl in IICcOniance with HUD's existing program reguJatio~ 

g<l'>"cming n:nt re~SOtlabknl'Sl5. tmd the rent ClItulOt exceed lhe [user of the: III reas.lD.:Ih le rent 

as detennioed pufSUiIJ\t to a r~1 comp:uahility study, and (l) thc P3}1I1C1U s!aodard 

estahlished by the PHA for lbt urut Slle Invoh·ed. This provI;ioo pertains t(, two m3in topic:;, 

one c(,ocerning whetber or !lOt a rent reasonableness determination i. required. Bnd another 

concerning Iheallowable renlle'>tl. 

lit...., \1o" ,"~ Pn::!.t..,; I'rr!.I001 Pn ... , OlE. S""" Via: p~ Chril I .. ~~...-Iy. PHl.I, V~ rr...s...J.tto,,""'lI: 

'r) . E. ~ ... . , VIC< P~ lr~cmalioIuJ; P,ul P.",d. v". ~k,u-eo.u.. ... ty R";w;....,,, cod O<·,d'V'M'l'; 

.\Ii. U.St)-ltS, Vi..'< rr~·c~IIIIll~~; P .... I. G. ThoOlp' ... ?HM, VI« 1'Tc::I1d<.K-1l ... !Ier ~~.~ ~~ 

[. Illboo. V',d·r •• idcn~Pro~kNl [)t\~ ScottlN, M, .. lr."J" ChiofEm"t1wOfti,):r 
96 


Whctha or NUl a R~nl Rea50nablencss DereIJlliomioll by Ibe PHA i, Required 

Und~r HERA, PI lAs are nN required to conduct II. rent reasonableness determination 

(in accordance with the e:<.istinS regllill.tiolls for Section 8 tenant-based and \'ou.:herbased programs) if the initial renl or rent ret\uested at SUbsequent intt'TWIIs. is equal to 

or less than the rent for otho!! comparable units fC{:ci\ing tax credits or assistance in the 

project for unil~ [hal are not octupi~d by S..-ction 8 Icnant-base-d or roj~ct-based 

assisted households. It would be hclpful if this point wa~ claritled in.HOD's final rule. 

To substantialt' our comment. please refer III subparagraph (a}(2) regarding Vuuchcr Progrdm 

Rent Reason3ble.u~s in HERA, Sec. 2835 - Olher IIUDPrograms Section 8 Assistance -

which SUites: 

"Section 8{oXIOJ of the United States Housing Act of 1937 (42 U_S.c. 

14371(0)(10)) is amended hy adding at the end the foll.,wing new 

subparagraph: 

" (0 T A.,'{ CREDIT PROJECI'S.- In the CIl5C of 8 dwclling unit rt'Ceiving tax 

credits pursuant to seelion 42 of the fnternal Revclll.!e COOi: of 198& or for 

which assistll.ncc is" provided under subtitle A of titl~ II of the CraMton 

Gonzalez N3tiolllli AITor,!able lIoll.'ling Act of t990, for which a housmg 

assistance contract lIot .subj(l;t 10 PJT'JgJ1lph (13) of this sUbse<:tion is 

established, rem reasonableness shall be determmed as otherwise provided by 

this paragrnph. c.tccptthal-

"(i) comparison wilh rent for units in the private, unassisloo locol market shull 

1101 he I't'\juiri:d if the rent is equal to or less Ihan the rem for other comparable 

units re>:eiving such tU credits or assistallCe in Ihc project thaI are oot occupied 

by families assisted with tenant-based asSiSl:m.JC under lhis subsection: .. ," 

A.llowablc Rent Level 

The st'Ction tilled, "Rent to owner: Reasonable rent" under IIL'O's proposed rule [§ 

9S2.507"(d{2)] stales, "[iJflbc rctIt r((IU~sted by the owner exceeds the UHTC~nts 

ror non-vou.:ber families, the rHA must perform a rent comparability study in 

a.;cordancc with program regulations and Ihe rent shall nOl CXCt'l.."'<I the lesser of the: (i) 

Reasonable rem as d~'1crmined pursu3n\ to a rent comparability Study and (ii) the 

payment standard cstablirlloo by the PHA for th<- unit size involVed." 

With the e"ception (lfthe intersection of n . .'ductiolls in annual FMR values by file 

percent {If more in IC-lSe temlS subsequent (0 the initial vou~her·assislcd lease, under 

IIERA, the initial rent requested or thc rent at inttrvals during subscquent lease terms, 

would not ~ "r~m reasonable" ifit cxcced~ the gre~[er of: I) tbe renl for olher 

compJrabk uniis ra:eiving such tu,~ ~fooit£ or assistance in [he prtljoct for units th~l 

art: not oc~upied by Sectiun 8 tenRnl·based or project-based assisted households; or 2) 

a PHA's payment standard for an applicable unit size. Vnd~r HERA, there could be a 

scen~rio where the initisl rem requested or [he rem 3t intervals during subsequentlcase 
97 


terms would be ··r¢flt rea.son:tble·· if it is etlu~l to th~ greater of 1) the !tnt lor oth~r 

comp~rJb e units reee il'wg such t!IX credits or assistance in the project for units tha i 

:u-e not occupied by Se\:tion 8 rerumt·blllioo or projecl·basro.tiSSl!ted households: or 1) 

a PHA 's payment stanJard for an applicablt: unit sileo Jt would be helpful ifthis pornt 

was clarilil!d in IIUO's final rule. 

To ~"UbslanlialcOUI comment, pleMc refer to subparagraph (a~1) rcgardmg Voucher Program 

RL'!tl Rmonsbkne5s in HERA. Sec. 2835 - Other HllD Programs S<":lion 8 AssiStance -

StalL'S: 

"Section 8(o)(lOj of thc United Slales Housinj; Act of 1937 (42 U.S.c. 

[437((0)(10)) is amended by adding at the end the following nell 

subparaSJlpb.: 

(F) TAX CREDIT PROJECrS.- ln the C<l!.C of a dwelhng unil m:eiving lax 

credits pursuant 10 section 42 of the InLalUll R~venue Code o\" 1986 Of lor 

which assistnnce is prclI'ided under subtitle A of title Jl of the Crunston 

Gonzalez National Affordable Housing Act of 1990, for which a housiDg 

assistance contract not suhject to parnl!,r.lph (13) !'Jf this SUilSlX:tiOll is 

established, 1'Cnl feasonabil'Ill'"Ss !iha!! be detcmrim:d as otherwlsc provided by 

thi!i paragraph. except th:ll- .. ," 

" .. (ii) tlit renr shall not be oon;ldertd reasonable for pUIJKlSes of tltis 

pl\l'"Jgraph ifit e.~cterls the I!.reater of-

" (I) the fCnts chargoo for othL'f cornpal1lble units rccm'log such iut credits or 

aS5i~tanee in (he project [hat are not occ~pjed by families assist~d with [('nunt· 

b~std ~ssislallCe under this SUhSL'CIlon: and 

" (II) the payment standard ~s\llblisbed by [he pubU,' housing agency for a unit 

ofille size involveJ. ' .. 

[xt ~nsion Tenns of nAP Contract 1§982.507(c)(2)1 

HUD's proposed rule is ioronsistent with the statutory language in HERA regarding 

cumulative tl.'rrn~ on extendiDg PBV HAP contracts. as well as with tbe intffil oftb<! Statutory 

IJnguage. 

Regarding the tmn oflfAP COnlraet extensions Illr!he PBV provam[§ 983.105(h)). HUD's 

proposed rule states. ~raj PHA Ill!!>' agree to cnM mto an extension at the [iUle ofth,· initial 

IiAP contract tCIIlI or any lime before expiration of the contract, for@additional tenn of up 

to ! 5 years if the PHA determin~s an estension is appropriir.lc 10 continue providing alTordllble 

housing for low-income fwni!ies. A KAP contrael extension may oot exceed IS years. A I'HA 

may provide for multiple extensions; however, in no clrcumslllncc rna.y su~h cxt~nsion~ 

exc-eed 15 yws, cumulatively"." 

HUO's interpretation of HERA also overlooks B number or imponJnlliSpects of PBV 

program S18.\UtOl)' hmguuge that were in place before HERA was enacted and that remain in 

place alier its L~laotmcnt. Section (a)(l) of HERA under Sl'Ction 2835 titled. "Other HUD 

, 
98 


Programs - PHA Projcct-Basw Assistance" amends H(o)(13)(G) of the Unit~\I SUites Housing 

Act of 1937 (42 U.5.c' 1437~o)([3)). As 1Im<:l1ded linda HERA. SI:,·UQn 8(o)(13){G) WIder 

existing lal\' states: 

A public housing ogcn~y may enter into II COOU1!ct with the owner of 3 

strue·1Ure assisted under a housing lIssistllllCC payment contract pursuant to this 

paragr,lph to e.~te!ld the term of the underlying housing assistance llayment 

contract fM such period lIS thc 3gcnC\· determines 1Q be BPProprilUe to a~hicve 

long-term aff<>n:iabitity of the liousing or to expandlHlllsing opporTUnities. Suell 

contract m9)', at !h~ election of Ihc publJe housing agency and tile owner of the 

structure, specify !hat such contrnct ~hall be c."~nded for l'('m.-w81 ~of up 

to 15 yeara each. if the agency make:; the llelenmnatlOn r«\uir..'d by this 

subraragrapb and !he owner is in compliance with the terms of the contract, 

Such a ClmlraCI shaU provide that the e~t~'1lSion of such Icnn &hal! he 

conlingrnl llpon the future availability of appropriated funds fot the purpose of 

renewing expiring contra~ts for assistnnc~ payments, as provided in 

appropriations Am, and rna)' obJ(gste the owner to MV':' sucb exteJlSious of the 

underlying housing assistance payment contract accepted by the owner and thc 

successors in interest of tho owner. A public housing agency llUly ngre¢ !Q 

enter intCl such a rontract at the time it enters inlo the initial agreo:m.:nt for Il. 

housing assisuncc pa:-'TIlcnt conlract or atllllY time thereafler that is before the 

expiration oftl)e- hou~ing 8.'!slstance payment conn-Jcl. 

The overriding public policy objccti\'C Mthe e":isting PBV statutory langu~ge as well as 

amended by HERA. is lhllt ~Ie cumulative number of years by which 3 PHA bas !he 

dismtional) euthority to c;<;t~nd 811 existing PBV IIAP contract wilh tht: consent oftll\: 

owner, dcpt'nds upon II PHA's infonned judb'lIlCflt300ut what ~~ rCa30n:lbly appropriate in 

order to achievc long-tenn atTordobility of the housing or to e;<;p3nd housing oppcmmities. in 

all cases, a PHA'sjudgmcnt on this topic is gcovemed by tbeir a.'>SeSsmenl of whether or not 

under the tenus contl'll1piated tor a pav HAP extension, tbe d\~dling units arc of sufficient 

quality 10 comply with HUD's Housing QU31ity S!and!lrds (HQS) through Ih~ dUnllion of any 

extended period of the pav HAP contract. The staluto/), language; in HERA also Slates Ihal 

·' ... such COl1traCI sball be extendtd lot Iellewallernl~ of up 10 J 5 years ~ ... ,. Congress' 

use of the word ··temu,'· and IJS(\ of the word ·'each" to modify J 5 years in Ihescntence abol'e. 

dcmonstr'JtCS that Congl"lSs· sI8tu1oryl!lnguage in HERA wus not inleoded to limit II PHA to 

e.t.1.end PBV HAP contraclS to a ·'term" of up 10 15 ycars exclusively. 

Determining the Rent 10 Owner (§ 98).301) 

Thl.': reaSOll8ble t('nt provision under HUD's proposed !'BV rule [§ 983.301(e)l states, 

'ltlile PHA shall determmc the reasollllbll.': renl in ac~ordallce WIth § 983.303. The rent 10 

Ihe owner for each Conlll'lCl unit may at nn time ~xcecd the reasonable rent. except in cases 

whm, upon red''1cnnination of the ltnt to owner, Ihe reasooable rent would result in a 

rent below !he initial rent." 

Section 2835(aX1XE} of HERA which ameuded Section 8(o)lJ3)(lXi) regarding rent 

adJuslmcllIs stalCS. "c;<;ccpt Ihat the CQntract ~ pro\ide tbal the m3~im\lm renl pennined for 

, 
99 


a dll'cl1ing unit shall not be less tban tbt initial rtm for tht dwelling unit under tb~ initial 

housing assis!nDI!C. j>.1yrtlcnts contract covering theunit;." .. ThcstalUlory language Wldcr 

IIERA allows but does IlOt require tb&tthe following slipulation be in Ib~ PBV HAP cootmcl 

Ilowever, if a PHA chooses 10 include this StipuJDlion in the pay HAP comr:tct \\1th Ihe 

consent of tile owo.:r, the la.oguage i.u HERA requires thai the provision stipulate the 

m9.,imum rent pennined for a dweUing unit shall DOt be less than th~ inil!![ rent for die 

dwelling Wlit und~r the initial hOl.l,l;ing assistance payments contm~t covering the PBVassisted Wlit 

Reasonable Reot 10 OWller (§ 982.507) 

The Subsl"CtIOn regarding re:tSOnable rent 10 oll'ner{24 eFR § 982.507 {a}(2)J Mates, "Ille 

PJlA mUSt redetemline t1u~ reasonable rent: (i) Belore any increase in the Nnt tu uwner. (iJ) If 

thm is a five Jlertent dttf'tase in the published fl,J[R in effect 60 days bdore the Contracl 

annivmasy (for the unit sile rented by tbe family) as compared. with 111(' FMR In tITer! I ye~l 

before the contract anniversary: or (iii) If directed I'>y HUD. (3) The PHA may :tho 

redetCTn'linc th(' rt!:lsonable rent at any other time. (4) At aH limes during Ih~ assisted tenancy, 

the rent to owner may not e:\cecd there:tSOoable renlaS moSt recently ddemrined or 

rcdctermint'd by thl' rHA." 

It is wonh noting that lillO's above regulations do not re\juire chaRge by the statutory 

language from HERA. The existing regulations which should remain in plnce lInder HUD's 

cl!lTent PBy mlcmaking. only require that for purposes of propcl1)' owner's annual rent 

increa~e request .. PHAs mustlmdertakc rent relsonahlel\css detennin~tion~ it7wben 

applicable FMRs decrease by five percent or !\lore. ntis existing rt:guJatil>ll, which should 

remain in plnce under llUD'~ I !ERA-related rulemaking. does flO! require PliAs to lower 

PBV (,wners' rents if/when applicabk FMRs decrease hy five percent or more, J~ has been 

diretted by some HUD Fillld Offices in some Instances over the yeJl'S, The rntetJ! of this 

regulation (§ 9S2.507(aX2)(i(i)] is 10 allim PHA., 10 i:(JndUct rent reasonubh.llt'Ss If warmotcd, 

bUlllQl fOT PitAs to necessarily lower the uxisting my !"Cnt in th~se ClreUmSlJntcs. 

Except in rh~ circums!an.:cs dcs.;ribed in our comments above rcgnrding dcrcnnining the relll 

to an OWlll'f (§ 983.301) coocenung inillJI rents, If under the cln:umstanc~s dcscnbed above 

regarding decreases in Ff',1R value~ of five percent (IT more a PHA receiyes a propcny (lwners' 

aunuaJ rent increasc reqLtCSt for Ii givl'll unit but a PHA's rent reasonahkllm determination 

justiiies the exisling POV rent. th~n!l PIiA can mmmam the e.~isting PBV rent, 

E~cept in the circumstances described in our comments above rt:gardiu!! detcrmining the rem 

to an owner (§ 983.301) con~cming initial rents, ifunder the circumstances described above 

regan!ing decreases in FMR values of five ~I\)ent or more a f'HA receil'es a propeny owners' 

annual rent iocrtase rt"quest for a given unit but a PHA 's rent reasonableness detcllnination 

justJGcs a lower PBV rem, Ihan a PHA can lowar the PBY rent to the rent rcllS()na~(e level bIll 

not lower than the initial rl'Dl. 

Some HUD Field Offie~ ~rsolllleJ have misinlel]Jreted and/or misapplied the PBY 

regulations gov~mi\1g reasonable rents in the. PBY program, which is why we believe that 

clarification ofll1c proper implemenUllion oflhis regulation b welcomed. 
100 


Remm'al or Unit fro[tl HAP Contract (2-' CFR 98J:!J 1) and ContioUlltio(l of Iiousing 

Assistance aYUl ell~ (24 CPR 983,258) 

HUO's propoS«! PBV rule describc5 when uruts arc 10 be removed from the Housing. 

Assistance Payment contract if.1 tenant's reol equals the total rent owed to owner under the 

assii'ltXi lease. HUD's proposed policy states the unit is to be remove<i from the (,BV cootract 

aller 180 d~ys has passed with no subsidy paymt'Dl, Both th~e proposed policies do !lOt 

provide a logical option to return units to tile PRV IIAP contract tfthe unit becomes ~vaiJab1e 

aod qualified (l£ain, if three years b!lve lapsed since Ihe beginning tcnn oflhc PBV HAP 

contract. n would be beneficialtQ program p!ll1icipanlS if the units could be al'~ilD bl c to be 

re-~dded to the contro~t ·'anytime." the contract is still active. 

Description of lhe PBV Program (~983.5) & l\hximum Amount of PBV Assistance 

Ii 983.6) 

HUD's proposed PBV ntle mcludcs inronnation colb:tion from PHA's in the following 

areas: 

(1) Thc total amount of 3DIluai budget !lllthority; 

(2) The percentage of 8l!Jlu11 budget ~uthority 3vaii:lble to bl: projcct-base.]: and 

(3) The total amOU!l! ofannual budget authQrity the PHA is piJnning to proja:t·b:t ~e umler 

this part ~nd th( number OfUllits that such budgct authority will support. 

lfHUD is going tn collect the following informahon from agencies. in 3n eff'on [0 minimize 

3dminiS[l1Itive bunll'ns 011 PHAs we recommend inclu~ a rcqU~1 fOl' tlJi~ infonnatioo in lilC 

PHA Plan SQ that PHAs thallUc utilizing the I'BV section of the PHA Plan can nnswer these 

questions ~I thll t time. 

TIl.1nk }ou for your considmtioo of our l\.'Commcodlltion5. Plcas( do nOi hesitate [0 contact 

us if you require additional infonnation. 

Sincerely, 

Jonathan B. ZiOUllennan 

Senior Policy Ad\·isor - lloU51ng A~ist:lllce Progmns 

• 
101 

RESPONSES TO WRITTEN QUESTIONS OF SENATOR SCHUMER 

FROM WILL FISCHER 

Q.1. Allowing tenant protection vouchers to be project-based in 

order to preserve affordable housing. 

Currently, HUD allows some tenant protection vouchers that are 

issued to be project-based in order to help preserve affordable housing and reduce tenant displacement. More specifically, HUD allows 

tenant protection vouchers (TPVs) to be project-based in the ‘‘orphan properties,’’ that have no option for rental assistance contract 

renewals and no option for long-term affordability. By allowing 

owners to project-base these vouchers, they can then leverage the 

rental assistance contracts to recapitalize the property. Further, it 

helps protect households that are currently residing in the property 

from being displaced and forced to relocate. 

With the appropriate safeguards in place, including tenant consultation and notification, do you believe that making all tenant 

protection vouchers eligible for project-basing is an important tool 

that will help preserve affordable housing? What are some other 

options to preserve affordable housing for low-income households 

that are facing possible displacement and rent increases due to affordability restrictions expiring or owners opting out of HUD’s programs? 

A.1. We agree that project-based vouchers are an important preservation tool to retain affordable units in a property for the long 

term. However, project-basing usually is not necessary to prevent 

displacement of current tenants. The large majority of tenant protection vouchers issued when privately owned properties opt out of 

Federal assistance are ‘‘enhanced vouchers’’ provided under the authority of section 8(t) of the U.S. Housing Act, which leaves the 

choice of whether to remain in the property to the tenant. Tenants 

with enhanced vouchers could be protected from displacement 

through enforcement of requirements in existing law for owners to 

accept the vouchers. 

Because of the language of section 8(t), HUD has determined it 

does not have the authority to allow enhanced vouchers to be 

project based, prospectively or retroactively. Congress would have 

to enact new authority to make such project-basing possible. Section 202(b) of the April 13, 2012, House draft of the Affordable 

Housing and Self-Sufficiency Improvement Act (AHSSIA) would 

provide this authority. 

Congress should enact this provision, but it should modestly 

alter the language to cover all situations eligible for enhanced 

vouchers (including prepayments in addition to cessation of rental 

assistance), require tenant notification and consultation, and require that HUD provide advance notice of the standards it will 

apply for waivers of the requirement in 8(o)(13)(C) that project-basing be consistent with the PHA plan and the goal of 

deconcentrating poverty. 

Congress also should drop the language in Section 202(b) authorizing HUD to waive the limits in 8(o)(13)(B) and (D) on the percentage of units in a project that can have PBV assistance and the 

share of an agency’s voucher funds that can be project based. As 

is discussed further in the answer to the next question, HUD 

should instead exempt all PBVs used to preserve federally assisted 

102 

housing from these limits but establish a new cap of 50 percent on 

the share of an agency’s voucher program that can be project based 

for any reason. 

In addition, enactment of the improvements to the PBV program 

included in Section 106 of AHSSIA would make project-based 

vouchers more attractive to owners and effective as a preservation 

tool. For example, these changes would increase the maximum 

length of project-based voucher contracts from 15 years to 20 years, 

require public housing agencies to prioritize making payments due 

under PBV contracts in the event of insufficient appropriations, facilitate the maintenance of site-based waiting lists that comply 

with fair housing requirements, set the limit on the share of a 

PHA’s voucher program that can be project based at 20 percent of 

the PHA’s authorized vouchers rather than 20 percent of its funding (making the limit more predictable and expanding project-basing capacity at most agencies), and allow PHAs to project base an 

additional 5 percent of vouchers for specified purposes. 

Regarding other options, we have two suggestions: 

1. Congress could authorize HUD to provide tenant protection 

vouchers for tenants residing in HUD-assisted properties with 

maturing mortgages or expiring use restrictions if sufficient 

appropriated funds are available for this purpose after addressing the needs of tenants in other properties, public or 

private, already eligible for tenant protection vouchers. 

(Prioritizing already authorized uses of tenant protection 

vouchers is important, because if funds are insufficient families that have been receiving rental assistance under other 

programs may be displaced and unable to afford other housing.) 

2. Congress could direct HUD to create a preservation exchange 

program that will identify properties that are at-risk of optout and facilitate purchase of these properties by preservation-oriented entities that will maintain affordability. 

Q.2. Exempting public housing redevelopment from counting 

against a PHA’s project-based voucher funding limitation. 

The PBV program limits a PHA from project-basing more than 

20 percent of its voucher funding. Many PHAs around the country 

have been using the PBV program as a tool to redevelop and rehabilitate its public housing stock. Recently, HUD has embraced this 

principle by allowing a PHA to convert its public housing assistance to a 15 year PBV contract through the Rental Assistance 

Demonstration program. Unfortunately, for many PHA’s unable to 

utilize the RAD program, the 20 percent limitation may still be a 

barrier for them to redevelop their own public housing stock. A 

simple solution would be to exempt public housing revitalization 

that a PHA undertakes from the 20 percent voucher-funding cap. 

This would then allow a PHA to continue to reposition its public 

housing stock and also continue to use the program in a manner 

that best serves the low-income households in the surrounding 

community. 

Would you support a change to the project-based voucher program that would provide an exception to the 20 percent voucher 

funds limitation for PHAs that use the PBVs to redevelop its own 

103 

public housing stock? Are there are other limitations or changes 

you would make to the RAD program that would make it easier for 

a PHA to redevelop public housing in a manner that protects the 

Federal investment and provides safe, decent housing for low-income households? 

A.2. PBVs are a promising tool for preserving public housing, and 

it would be beneficial to ease—but not eliminate—the limitation on 

the share of voucher funds that can be project based if the added 

project-based vouchers (PBVs) go toward preservation of public and 

other federally assisted housing. Congress could achieve this by exempting PBVs used to preserve federally assisted housing from the 

20 percent cap in 8(o)(13)(B), but providing that PHAs may not 

under any circumstances project base more than 50 percent of their 

voucher funds (or authorized vouchers, if the change in Section 106 

of AHSSIA is enacted). 

This 50 percent limit is very important, for two reasons: 

• First, allowing the majority of vouchers or voucher funds at an 

agency to be project based would undermine the PBV program’s resident choice policy. PBV residents have the right 

after 1 year to move with the next available tenant-based 

voucher. This is a vital feature of the PBV program, since it 

enables the owner to leverage assistance for underwriting purposes and residents to benefit from the stability of projectbased housing, but also permits residents to move if needed 

(for example, to pursue a job opportunity) without giving up 

rental assistance. 

For the resident choice policy to work well, however, the pool 

of tenant-based vouchers must be large compared to the number of PBVs. If too many of an agency’s vouchers are project 

based, PBV tenants who wish to move will experience long 

waits and few vouchers will be available to unassisted families 

on tenant-based assistance waiting lists. 

• Second, if agencies project base a high percentage of their 

vouchers, lenders may be less willing to finance rehabilitation 

with loans that rely on PBVs for repayment. It is more challenging to foster lender confidence in project-based vouchers 

than in Section 8 project-based rental assistance, which has a 

longer track record and is backed by direct multiyear contracts 

between the Federal Government and owners. Moreover, Congress has underfunded the voucher program a number of times 

in recent years, with the result that HUD has been compelled 

to fund agencies at levels somewhat below the amounts for 

which they were eligible. The deepest shortfall to date, in 2006, 

reduced agencies’ funding by 5.4 percent. Funding uncertainty 

and the potential for shortfalls may well increase in the next 

decade, given the constraints already enacted by the Budget 

Control Act and deficit-reduction pressures. 

Project-based vouchers have been largely insulated from voucher funding shortfalls because they make up a small portion of 

agencies’ voucher programs. PHAs can cover shortfalls through 

temporary and usually modest cutbacks to their tenant-based 

vouchers (for example, by shelving vouchers rather than reissuing them when families leave the program) without affectVerDate Nov 24 2008 09:17 Apr 26, 2013 Jkt 048080 PO 00000 Frm 00107 Fmt 6602 Sfmt 6602 L:\HEARINGS 2012\08-01 & 12-11 HUD S RENTAL HOUSING ASSISTANCE PROGRAMS, 
104 

ing project-based owners or their lenders. If an agency were 

faced with a shortfall and most of its vouchers were project 

based, however, the agency could avoid PBV cuts only by making such drastic cuts to their smaller tenant-based program 

that current voucher holders could be forced to leave their 

homes. And if the shortfall were deep enough and the share of 

PBVs high enough, it could become impossible for agencies to 

avoid PBV cuts. Even the prospect of this occurring could make 

lenders less willing to make loans that are backed by PBV subsidies. 

The Moving-to-Work stakeholder agreement incorporated in Section 401 of the April 2012 AHSSIA draft recognized the importance 

of maintaining some limits on project-basing. That provision would 

permit MTW agencies to project base more than 20 percent of their 

voucher programs, but only up to 50 percent. 

Another provision of the PBV statute also impedes use of PBVs 

for public housing: the cap in section 8(o)(13)(D) of 25 percent on 

the share of units in a development that can have project-based 

vouchers (excluding units made available specifically for the elderly, people with disabilities, or families receiving supportive services). This cap is beneficial and important when PBVs are used in 

newly assisted developments, since it encourages mixed-income 

housing (which can place greater market discipline on the development’s management). But it makes little sense in developments 

where more than 25 percent of the units already receive Federal 

housing assistance. It would be helpful if Congress specified that 

the cap does not apply when project-based vouchers are used to 

preserve federally assisted housing. 

While these changes would be worth making, on their own they 

likely would expand the use of project-based vouchers to preserve 

public housing only moderately. HUD has increasingly implemented restrictions on public housing demolition and disposition to 

further preservation goals. These restrictions are important, but 

one of their effects is to impede voucher conversions solely to finance redevelopment. Moreover, when conversions are permitted 

the funding for new vouchers would need to come from the limited 

appropriation for tenant protection vouchers, which has been cut 

sharply in recent years and is close to or below the level needed 

to meet the existing annual need for new tenant protection vouchers. 

RAD, which Congress authorized in 2012 appropriations legislation, permits conversion of up to 60,000 public housing units to 

project-based vouchers or project-based rental assistance, but prohibits HUD from setting these units’ Section 8 subsidies above the 

amount they would have received through the public housing operating and capital funds. This funding restriction, as well as the 

unit cap, will limit the share of the public housing stock where 

RAD is feasible. Large-scale use of project-based vouchers or 

project-based rental assistance to preserve public housing will likely require a decision by Congress to approve additional conversions 

and appropriate the modest increase in voucher or other section 8 

funds needed to set subsidies at adequate levels. 

105 

RESPONSES TO WRITTEN QUESTIONS OF SENATOR SCHUMER 

FROM LINDA COUCH 

Q.1. Allowing tenant protection vouchers to be project-based in 

order to preserve affordable housing. 

Currently, HUD allows some tenant protection vouchers that are 

issued to be project-based in order to help preserve affordable housing and reduce tenant displacement. More specifically, HUD allows 

tenant protection vouchers (TPVs) to be project-based in the ‘‘orphan properties,’’ that have no option for rental assistance contract 

renewals and no option for long-term affordability. By allowing 

owners to project-base these vouchers, they can then leverage the 

rental assistance contracts to recapitalize the property. Further, it 

helps protect households that are currently residing in the property 

from being displaced and forced to relocate. 

With the appropriate safeguards in place, including tenant consultation and notification, do you believe that making all tenant 

protection vouchers eligible for project-basing is an important tool 

that will help preserve affordable housing? What are some other 

options to preserve affordable housing for low-income households 

that are facing possible displacement and rent increases due to affordability restrictions expiring or owners opting out of HUD’s programs? 

A.1. The National Low Income Housing Coalition (NLIHC) thinks 

that project basing vouchers, as either tenant protection or enhanced vouchers, can be an important preservation tool that safeguards tenants from increased housing costs and helps retain affordable rental housing. 

In most cases when an owner opts out of a Federal housing assistance program, residents are issued tenant protection vouchers 

that enable them to stay in their homes, or use the vouchers to 

move if they choose to. However, there is a small subset of HUDassisted properties with maturing mortgages or expiring use restrictions that are not eligible for tenant protection assistance once 

the affordability restriction ends. The FY12 Appropriations Act provided up to $10 million to provide tenant protection or enhanced 

vouchers for residents of these properties located in low-vacancy 

areas (the ‘‘Durbin-Brown’’ provisions). The FY12 Appropriations 

Act also allowed HUD to project base that assistance, which would 

preserve a property’s affordability while enabling tenant mobility. 

Beyond FY12, Congress should continue and augment appropriations for tenant protection vouchers for all tenants Durbin-Brown 

intended to assist (HUD is making only $6 million available); plus, 

the provision should be modified to remove the limitation to lowvacancy areas. 

The ‘‘Merkley-Brown’’ provisions of the FY12 Appropriations Act 

should also be expanded beyond FY13 in order to allow ongoing 

project basing of vouchers, in lieu of tenant-based vouchers, when 

Rent Supplement (Rent Supp), Section 236 Rental Assistance Payment (RAP), or Section 8 Moderate Rehab contracts expire. 

In addition, Congress should amend Section 8(o)(13) of the Housing Act, explicitly stating that all tenant protection assistance may 

be in the form of project based vouchers, eliminating the 25 percent 

cap on the number of units that may be project based at federally 

assisted housing. The Merkley-Brown provisions authorized HUD 

106 

to waive most features of Section 8(o)(13), but in the Rental Assistance Demonstration HUD merely raised the cap to 50 percent. 

Eliminating the cap and increasing the maximum contract length 

of a project-based voucher contract from 15 to 20 years would make 

project basing a more attractive and effective tool for preservation. 

Finally, Congress should establish a national preservation inventory that is publicly available and regularly maintained, requiring 

HUD to provide each federally assisted property with a unique numerical identifier. This will help residents, advocates, and preservation-oriented developers identify properties that are at risk of 

leaving the affordable housing stock so that preservation-oriented 

developers can take the necessary steps to preserve properties as 

affordable housing for low income people. 

107 

ADDITIONAL MATERIAL SUPPLIED FOR THE RECORD

LETTERS SUBMITTED BY DIANNE HOVDESTAD 


MOllllra.ll l1ains 

1OS t<l< .... _ tt I0 30104 

March 20, 2012 

Assistant Secretary Sandra Henriquel 

U,S. Department of Housing & Urban De~elopment 

Office of Public and Indiarl Housing 

451 71h Street S.W, 

Washington, DC 20410 

Dear Assistant Secretary Henriquez, 

~ ...... It..-.t 

• • 

The Mour'lla;n Plains Regional Council of the National Association of Housing 

and Redt'velopment Officials (Mountain Plains NAHRO) is a membership driven 

organization that exists to provide prO~5slonal developmefll, advocacy for pOblic 

hOl.lsing and community development .. geodes to entlance Ihe affordable hOUSing 

industry and promote Viable commuflities In our reglofl. Mountain Plain. NAHRO 

has over 200 member agencies and represents housing authorities and community 

development agendes in Colorado, Montana, North Dakota, South Dakota, Utah and 

Montana. Nationwide, NAHRO consists of 19.900 individual members and associates 

who provide housing for over 7.9 million low-income people, 

The purpose of this letter is to cOflvey the serious impacU Ihe federal budget cuts 

ha~e had in our region·s communities and to urge you to push for regulatol)' relief. 

Our Mountain Plains NAHRO members operate successful housing and self-sufficiencv 

programs that serve low-iflwme wcrkiflg families, seniors, Veterans, and people with 

disahilities. 

We are seekmg your assistance i!1 f.;cilitatiog the Implementationof the regulatory af'(! 

administrati~e relief changes retomrneflded by NAHRO and other indistry leaders. 

For several years, NAHRO leaders have worked in good faith with HUD offiCIals on 

sound and responsible regulatol)' relief, however 10 date. HUD has failed \0 make 

significant changes. 

Public Housing Authority leaders are forced to make difficult decjsions in order to 

manage these devastatil"lg program funding cuts. Sil1ce the adminIStrative program 
108 


functions require human resources, staff reductions are the only wts that can be 

made. Decreased staffing levels equate to decreased abiliW to administer program 

requirements, creatirlg a vicious cycle. Through staff lay·off~ or re·hirirlg freezes, 

Housing Choice Voucher programs are being operated at bare bOrles le~els. Because 

the HOusirlg Assistance Paymerlts lor families' rent has been fully funded in the Federal 

budget, the number of families served has remained constant, but PlJblic Housing 

AlJthorities must administer the same number of vouchers with Insufficient staffing 

leve!s. To date. neither COrIgress nor HUD has implememed arlY sigrlificarlt regulatory 

or statutory changes to the Housing Choice Voucher program which would materially 

impact the compliance and adminis!rati~e burden of the program. Without regulatory 

relief this year, Public Housing Authorities face the dire prospect of inadequate service 

levels to families and/or noncompliance with over-complicated regulation. 

Last month, HUD issued Notice PIH 2012-15 which suggested administrative charlges 

Public Housing Authorities could make to cut administr.!Iive costs of program 

admirlistration. unfortunately. there were no regulatory changes in this rlotice arld the 

suggestions were things that many housing authorities already do. Much more needs 

to be done in order to manage through this challenging funding period. Mountain 

Plains NAHRO is requesting that HUD act as a partner and ally in immediately 

implementi[1g meaflingful relief to e[1sure the future viability of these longstanding 

and proven programs. Only through collaboration and advocacy can we ensure 

that the people we serve are not the ones who bear the brunt of the underfundjng 

of these vital programs .. We urge you and HUO Secretary Donovan to implement 

the regulatory and administrative relief efforts recommended by NAHRO and other 

industry leaders. prioritizing revenue gerlerating and cost saving reforms such as those.' 

highlighted here: 

L Simplify income verification by enacting provisions relating to improved 

household income and asset determinations by enabling Publlc Housing 

Authorities to use participants' actual past income from the previous twelve 

months or current income as anticipated for the following twelve-ITJoflths. This 

specific item from the original "rent refinement" interim rule is something that 

HUD can do now through regulation without having to introduce legislative 

language or wait to have legislative language enacted into law. 

Other iflcome reforms that should be prioritized include: 

a. Allow households to self·certify asset:5 of less than $5,000 

b. Allow Public Housing Authorities to apply applicable annual adjustment 

factors to filled benefits or income verified on HUD's EIV system 

c. Eliminate requiremeM to verify "excluded income~ items 

d. Allow Public Housing Authorities to use pay stubs to verify income as a first 

ranked item 
109 


e. Allow Pliblic HOllsing Alithorities 10 lise re-certifications from other meanstested programs 

II , Allow Public Housing Authorities to use their unobligated Net Restricted As.el 

tNRA) funds from prior years to increase orlgoirlg Administrative Fee pro-rations 

which would help the HCV program sustain the number of families served last 

year and facliltate the Departmeflt In accompllshi'lg its FT 2010-15 Strategic Plan 

goals. 

III. Where possible, suspend or waive all or portions of the Section Eight 

Management Assessment Program (SEMAP) which assesses Public Housing 

Authorities' management of this program. Taking unilateral action to suspend 

compliance and reporting burdens until fun funding of Administrative Fees is 

restored will allow Public Housing Authorities to focus their limited resources 

toward service delivery. NAHRO raised numerous, we ll documented, concerns 

over the scoring and Implementation of SEMAP Indicators. Mountain plains 

NAHRO believes that under tUrrent conditions this would be a good time to allow 

the most recent scores to be carried forward until all issues are addressed. 

In addition to the critical Housing Choice Voucher program relief efforn discussed 

above, there are additional measures which HUD can take immediately that would 

assist Public Housing Authorities to more effecti .... ely manage their Public Housing and 

Community Development Block Grant programs. 

IV. Asset Management regulations came out of a NNegotiated Rulemaking" 

conducted in 2004. Asset Management costs/fees were bench marked to a 

model of fHA-insured properties. Mountain Plains NAHRO believes that these 

fees should be re-evaluated as part of the Federal Advisory Committee process 

reqUired by the regulations. NAHRO sent a letter to HUD addressilg concerns 

about the Operating Fund rule and its Asset Management provisions on 

November 11, 2006. 

V, We strongly believe that the Asset Management requirements of the Pllbllc 

HOUSIng Operating Fund Rule are extremely burdensome for smaller agencies 

and do not pro .... ide any tangible benefits. MOUntain Plajns NAHRO members 

urge HUD to raise the Asset Management threshold from 250 units to 400 units 

immediately, 

VI. Extend the CDBG timing requirement for updates of the required Analysis of 

Impediments to Fair Housing Choice (AI) or allow Elltitiement Communities to 

determine when such updates Or revisiorls are needed based on local conditions. 
110 


VII. Revise the HUO requirement regarding CDBG on-site sub-recipient monitoring so 

that is based on a minimum dollar threshold, 

VIII. A.llow forformation of HOME Consortia without requiring each jurisdiction to 

alter its Program Year to cOflform to the priflcipal organization's Program Year 

where an organization already has its own established Proglilm Year. 

IX. Eliminate the excessive financial sanctions that result from (DSG funds unspt'nt 

in e~cess of a ratio of 1.5 of its annual entitlement and create a more reasonable 

way to ensure communities are effectively utilizing appropriated tunding. 

Mountain Plains NAHRO respectfully urges you to support the deregulation meaSLlres 

as outlined in this letter and asks that your office convene a meeting with appropriate 

HUO senior officials and NAHRO members to reach consensus on the requested 

program reforms and develop an expedited timeline for implementation by the third 

quarter of 2012, Mountain Plains NAHRO along with our peers from the five other 

states that make up Mountain Plains NAHRO Will be meeting with our Congressional 

delegates as a part of the NAHRO Legislative Conference to revlt'w and further explain 

this information. We look forward to meeting with you alld other Key HUO leaders at 

that time to discuss how we call best move forward togethe r Oil these initiatives. 

Sincerely, 

Don May, President 

Mountain Plains Regional Council· NAHRO 

Craig Maraschky, President ~.., 

Colorado Chapter - NAHRO {olorado 

SueAnn Grogan, President 

Montana Chapter - NAHRO 

Terry Hanson, Pre5ident 

NAHRO 

North Dakota Chapter - NAHRO 

John Stengle, President 

South Dakota Chapter - NAHRO 

lynell Smith, President 

Utah Chapter- NAHRO 

Greg Hancock, President ~ 

Wyoming Chapter. NAHRO 1m 
111 


r 

..... ; ...... •• 

"",'WI"(.,.,.,,,.. 

" ... \~""''''''';\l'''' 

MI 000 ~hr 

''''''''' 

t;.s.lll:r\mlL\fllfllOUir,.(; ~lIlU~\ I)[IUQ,m ::.-r 

~''lIl''':n;''<. Pl.' lIIMI-~M 

~lollJ1l.1m rlaJl\!·Re~ COIUlCl i 

NailOWi ~ of I~ Jnd Rnlt-.dopmaJI OffiClIl, 

11o,(ICoIo:o!\Q 800lMld 

(omnxlte City. CO SlXm 

DeW.II! ,Iby; 

Th~ you!'Of)= 1<"t!.:I rrilpQo,,,,dw BUD anoJ ~A RO pan .... , logether to 

mipkmtm ~gwl!!«y mitr. The 0Iftel: of PWbc JDd lDIIiln 11iMm, (PIH) i> IIII<:!t:MaIIII 

!cl0fm)'~ W'C~lIb,., l'CIf.Ii~I'II!. m.Ioo: mlll,sum,l1: ~ rrw~ bell~ bus~ 

pr:di"~1 ~Ild ~Iso n .. ~ PIli Ol'i',,'lht te5pOOSib,lit,et,. 

PIH h:l!, l$rnJ lr:wNllp IIJk:uK! M"(II\aI "llh illo.lu>!ry P'WP' ;ulIl.J!llCl' IO",,.(t k~y 

pro.i'llllfl.' or 11'1:: d~H'" II:aIi of the AFfl)rtbhk 1I0lbll1& iIIII ScIf·SllffIl.=-')' 'OII:(11'(1IlCII 

Aq of 101! (AHSSIA!. mc.1l1lmg ,,~]flGlUly ~pmJ!IIg the Mll'ling IQ Wurt pmgr:lm 

III :IIIililloR, our fY !Ou bW,n JlIllIIO'n ~iu1 Qlt3mllIIIIIg errtJ(1) \lid! a: ""=nnl~l 

Inlpel.llO<lS of 1l0U>1nE: (Iioict Vooc:bcr (HCV) Unit!: Iwlmruy 10 l'fl:JU: l'OllSOllll or PIl,\s 10 

npmIr public hotII.~~ Aulbibty 10 ''''''/I/.ally l"OlN~.u.C fuadll1l forlNdm; ;Up(QIl'~ 

.,m'!O: ;ll.11~illO ~ ormt"'" t;lpK:>l1llld So!c:!i0n 8lldmlnl"I':IUVe fill: fUllchn, 101111.1:', ~ 

~lIwnl)" It:> 'f'OI~·bN ~"is.t:ull1: III up 10 fi.,. ptrWfII pf IleV ftlllllln~!1I' bl~ 

1I\IIi'~. W l.I!IIilio:s III onIer 10 I'fIl'IIk boo.mg arW 'ft\')[(S. To hOOI .unrhfy lilt i'l'\>gr.lltl 

~ 

III1d rNlli,:C the ~nlln,-u:.I"c P"ruCIIIHI I'!lA. In:\! 'lIOn 0lIId n\Jmg~ Ih~ proprnlf', the budgel 

10 l'l>ll'oblll!: ~ -qoocc fI(ltnIDII inI ClpII.d n...b IIUO I ,.""bbc hlMlI'It ..-dy 

\Utw. ,\" fiN IttptOIUrd tlnl <.'\III'>oI.Ul~ .. , lhcbudgrt pm''''''\~l1 PHAI "~h full 

Il~,ibthly 10 uw ~It vrcllllmg IIId C2j'1lr.1 fundI for:lllY di!IMr c.1piWl .... '","*lIIg Uf'CII'C, 

,\11<1, I!UO\ ~l<l~,~ 1'fOI'O'<"i' J~·PlU) hilUlII>C, ilIl c'iJo:m':-b~"-'II \lr:II~gr fur 

"1C1rn1~ cmplu)'!UIl Uf'I'OIIIIIUtIb:nl nnUlIg.i d l"'''Iic' lu,,,ltlg 1bof.Imt} tbmupr ~ IIwtt--

IIC:m! t-"!I:11n III cmpl.l}1lIt'fII \1:1' iC(', rtIII-!I.:a~ \\00; Hilmi""', oIIl\I \Umnl~n'ly \\If'l'lm for 

".<Ie 

\Ilhc '~nlC ""IC.lu rollllJ~1C "npkm~lu;u~1n uf iIII: (I~al J\,">I:IIIl'I' Dcmor<srrlll~"f\, 

11M: ~1t1L'III ""lllI>rfOl!Lbn,~ 1111/10 "'~ r .. ell>lll'l¥ ~!{Itn-.Llll: tb 

l"f'\'~ uf on'll. I"ntkd Ihf1llll.lllh.' publ" 1Mi'~11 and >lH.';li1l'1l ~"'fII1"' l'rumm,'" ,'JII 

k\«l~~ JotM 1\l1I\,\'r" I"";.te C.1plI,u :aid 1'ft'<'I'! ..n~ hou,.lfI!l 

k'~r.II I~ IIii:' I\'\\lIll"'trnJ,llM~1> ~I ),)m kll~r:.no 1M t>f \JIS~I,\ ~lo:lw 'II~ ' '1II1phf)m~ 

"""'-'"It' '..,1111,;"' .... ~rnlOClUl!: r'M,4." mOll,,! ~\ 1"'I"'II''Il ~oJ ""t~nr;nl "' ..... 

J~ltm'I",~."f\' I>y I:IUI>IUI~ I~I ,\, 11111" li-,nM'l"IlIb oI((II~II\,o'1 101<.'"'11' f~mllho: l"t"I\1U' t ~ 

....... - ............. -
112 


InoNb, ar alMIllIIL'OIIk' It) .lohopalCII fOi 1M foI~ln! l~ month...: ~11O'<I1II!l ~ 10 

..elr<enUy ~i Ii bs 1ft.1n SHK.o; &lid IJkN In~ PI/A, 1(1 ~y aJlIidllt \!mUll ;l!JUOlll1eIU 

fxlOO; IlIll\Cd b.'ndits or 11'k'(lll1C 'mfitd 00 HUO'< Enlnpn..e 11lL~ Verif":3fion (EIV) 

\}\1~m. A>)W know. If AlISSIA I, 110( tllJl;ln1.IIu:S( dl:ut!r.\ ",·uuJd rrqulrr IlUD ollC1lla~ln! 

before th..'y .'()uld w\;( ~ff'"(.1. 

Se\~ of Ille SitW-<tiorb; (r\lm J"'" Irtltf I1I"e IHIder o.\e'.·e~ III\:ludint: ~ noc~ 10 

(lill\lll.llC ~ r~irC"mC1lll0 ~a1fy ··~\dIOlJrd 11ll'Oll1l'·· Item. ad iIIIlZp(blt 10 Noll«, PIli :!Oil)· 

1~. AdoIMumrl;.t c;.,;'J.I1Io."t I .. , f./ftflr.y 1IIII/lIunoklstJ u.., 'f /Itt EN SOl/till. ~ 1m) t.: 

fl\l~M III t>bbIt>h J lII'OI~tIof. poop to funlier ~'<£"\1S5 I»-J:OIIlI EIV 1S.'IIt:I 

Yo nb ~ 1<1 ~1OI111( "',\t1 1IUII.1~ fen:l> I'J" ,,( the FfIIml AdYJ>ory 

("nmllllll~ ~'.1II11t,. hflll" 1'111 " 1001\01111 an IJIo.o ~ ro roo"iok 1I1 PIiAi '" Ilh 11111 

!kl.b!I~y 1(1 ~ r:.pl!aI ~ ~ID' fklnl~ fI)f :Illy diP* ~ 01 opmIlDI t.lpI'IbC. Tlus 

",·,I1tm1jllcte the rnn;~oOn 10 mo:I 1lIJIIJ~ ilmplify the prop3rll.lIId m.lUll' 

IIllI!Unt!olr.ltI'·. burdai. ."'j )011 know, PIIA" u"'us~y ~1:d.i,es.1I!d IIdI'lXX)·lf"OUl'" 1ft 

~'llti"p.llll1g In fe.:dhxk \r>.1""" IIbout 11m ~1. 

With r\')pa:IIO til!' IUW'''''"'" 10 ,u'ro:oo or ~Ive all !II" [IDII1f'M of the Stc!I<ll1 F.lghl 

.~ :lII.!emtnl ",,'C"mtnll'rl~fSEMAPI who.:h :l>.>t.<~ public IlotnIo!AWttIt<' 

m;u\,1~nrnt of the HO\I,mg ChoJicr. V<lUI.ha" ~,", [du 001 <,uppoo ~ocb ttI1 :I[lII!IIadI 

b.:\~ l!\;IIIy SE.\LAP looioloo 1IIU'iUI"t '121l1!1f)' ~1ImIml!, "b,n the ~M Iu5 ~ 

~j)jlity kI ~ iIIl: belli' met. 1\oIo~,tt. PUI ",II' mOlIna- ~E. IAP!.an> ZJLIlf IbM 

:In: "p{1\..;IrII dtop!. III prri\Jl1lWK"t' r,KlIlp :IIi ~ n:wIl 01 tbe ~ ill 1dmin.1U3IM fl'C 

futxhn! \t'o~I). pnl ",·!II o;pku. ~cahtl pohey 01 admll>i>tnli,l' ~ tlul CIIUld be 

II1IplomalItd 111 ~ ~lplTr!alll1kmN> III rliA ptlfonn:n..e. 

A .. )UII nl:l) know, [IUD IS "'IIIt1", 00 dl:lllSCI to lile SE.\IAP ~km. ~ "dl ~ 

mlp!<'u·.'llIlum!lf the Ne.t1 Gtr,mtlOll M:w~ Sr.>Itm. a lw1lh.1l "iU rnh.mc:t filWUll, 

runflJlill. 1II11l1Ppli<;l/ltI!rnJl\! d:lta 1IIWIcag<II\f1l1 1111'lI{gfllhC>t imll:iUI·cs Pl!n Qlla\1 t! III 

.nifl (Ilt II>~'III<'TII oj rUA. pctf(lM1l;u"/,."!: flom!otlf<~nlf\c:l(~IIO;~ '\11fl(~li!lll.:o.' 

~ til UII!I r):1}· ('" iliIl~ tim (be fkr:mn\flll aJrc.ll.ly hIlS. (I1(n"lly n"l!l$ing Ihc :ll,"lnl\.lr~II't 

IIIlnkn lI.'.;\;I:IIeIl "uh We SE.\L,\I' ,miflQllU!I proccu. TItt> tkp.ulmcnt j, 1.1<.0 tII1O.lcriaI:lIlg (II] 

IIIIrMl".r:tII\C Ii:\: "iluJy II' IlIlIy ~,·~11l,1I{ Ihr ",ri" ut IIUlmn, i1II .!t<.""l.l"1: .our;h.:: pnwam. ""'-

(t,"II' 1>1" lilt: "tidy ",-ul he II>N n. j~"lfy. (t' 1'1lIfI bIllie lllm.'IIIlIdmllltilrlu.e fte r,oOOlili 

f,ltJOOb ~ fltlurt ~M II.~. lk ca~gcmem ,~ WI> "taly iql!N1lI! ibt 1kp.In1llC1ll., 

""nnlllnn w CllWIre PU,\\ 1IX ... , 'c ~( wmp.'n>;II1OO lar m.:1f ... ·:n.a. 

..... "" "11tt ~IM> tmlll )\IUf kiter ~IR' 1ty.!31d1 iII3I PIli " .. 11 

pl.lI"\UI'Ql oIIlh" '"'It': (, .. ."ludll~ Jlk'lling MIl( I\IIII'Uij\UIbo. ... ..:-. 1(1 ~-c lM"C1JfClItII~ 

'I'UInOihn nlnln>J~ ~n,; ~1~]"tII~ IV>I .. JI' mlll~ AU/bono:,;>!" lI>t tlttU"u ... thltpl'"<l 

\,' RNlI(I'"<I .\"Ci j~R"llwkb frum poor )\':II' KlI~·!I.'a..e,~ AtImlll"'l\IIl~ FI'C pm 

r.l1~~I'. ~lId r.11>1II~ Ib~ \,>tI MJI"'¥'~"U\llh!~>Id fo'lll ~."'IIII1I, 1,,-Ilfllllli15.. 
113 


~1cJM: COO11K.1. !Jch GIll> ... Dq:Iuly .'\,,';1.t!lI Sc:ctewy for P/llic~, 1'njgJ1Ul1~ .1111 

L.:gl,I~II\r IIU!IaIMI. :u ]l~-Iti~-I1).l1. if ~ ha'~ funhtT q.1<'.'Ili\lllS, 

~'t", CI':I:g .\l~i'Zchky 

SI)C'Armr.I'I;I~1 

T,ny Uanson 

JoonSlcnglc 

l)nrllStnilh 

GK1 11 8OCOC ~ 

SillWtly. 

/ :6",'-_'-'-,'7. 1I"'0< ",,"'"1-...'77'\ A~'hlnnl S«rt12l')' \j 
114 


N.l.H ~O: ~tllt-by-5I.itf P10jKled IfIIJl.lCl on the IIumbH Voume. Househcld> Th.ll Would 

h le.ued If PHAs ~KeIve 8J P!I'(ent Admtnlllrlli'le fee Pro-Rations (o.!Dbo, 4, 20111 

fewer Number 01 Percen' 

.l.VO!I'.Ise Numllotr o' voucher lIOUIeI!Dldl ReOuction in 

Voucher HouseM.ldl lrued OVer I rweM! Voucher· 

AVO!I'IIp "'umber of Projected 10 Be le,nerl, Mor1t~ Period, .III ..... ItneclVO!Kher if "".1.1 R«ei'Ie aJ Res"~ of 83 Percent House1lold\ 

l!cMe/IoId\ fl of Perret1lfo(1minillTJIM .I.IIm"ittrllM fee CMr.T""!M 

Stitt I Territory MlldI)),201l 1ft I'fo.rations Pro.raliom Menlh PIlriod 

.... 4,244 ,~, ,. 

.l.liilamf 28,949 V," 1,092 • 

.l.rUnlJl 11,m lQ,m m • ."lIII 'J 20,410 ,,,., '" , 

calijO(l1Ii1 l8&,OIO m,IS9 11,911 • 

(010'0110 19,004 28,m '" ~ 

COnnt<li<u, n."' 12,11iIl 1.l01 , 

Dlstrict.ot(oIumb'l 10,116 ~,r.6S 7U 

... ~" 4,m 4,189 ~ floridi 81,165 84,474 1,691 " " "" .. ~1,.4S9 49,7115 1,674 , 

Go •• 1,391 ',", " , 

HIWlIij 8,562 8,329 m 

... 20,984 20,1/4 ... " • 

Idiho 6",698 6,08 'W • 

IUlnoil 11,341 72,882 4,459 , 

Indilnl 34,ti64 ll,1iIl7 1,05? 

Kallll$ 11.41;8 U,128 ~ KentIK!<y 31,891 '" ~,'" 1,059 

\ouftlinl <IO,m " " .... 2,213 , 

MillJ(/lUSftU 11,131 .,'" 3,564 ~ 

MlrylJnd 4O,m 39,118 1,S'lS 0, 

Mault 1I,m ll,rI9O 

Michipr> Sl,m 5O 18~ "' .' "" ,

M;'nelOt;! lO,1IS9 IJ,fn 1,Iil 

MillllUri JlI,fi18 ,>7,646 ., : Mi$l~sippi 11.]]9 n,MS m 

Mantan, S,sSO S,11W ~ NortllCifDlinol Sl,l64 !oO,./5 1.188 '" .. North Olkall .,'" 6,M9 ,~ 0 

Ntbr.IU "" ". ,~ 

Iffiy IilmW! f 9.1~ 8,81~ .. " • 

Ntw Jertty ~l.IM 501,282 2,882 ; 

Ntwl.lt,d«l 1U38 ll,m ., • 'm. 13,~50 ll,m ,~ , 

NtwYork ""m 196,919 1l,Wl " 
115 


N.l.H~O: Statt-by-Sl.ilf PlOJKled Imp.lClIIn tM Num~ Vouthl!r Housellcll» Th.lt Would 

Sf~.ued III'ItAs RrceiYe 8J P!ftenl AdminilltJI;'/! 1M Pro-RatiollS (O<tDber 4. 20111 

ftwer Number 01 Prrtfnl 

.l.vm£fNum ~,ol Vouthrr lIO\IIeI!DldI ._. 

VoOOIrr HOUlf~DldI lusH Om' I lwelYl! Voocher· 

Al'flip 'lumber of ProjfCled 10 Sf LNsH, Mo!1lh Prrlod,.l11 AISJsItd 

IfnedVOIIdIer if PH.I., R«eNe 8J R~"1t ot 83 Pf'CeIll HOIIsthoids 

lIMel!alds JI ot Prrtf" .l.dmin;!lU~ .l.dm;";StriliYdM ~rJtWft.! 

Stm/rerr!toly M.,ch31,2011 fMP<o-rJlkutl P'(\"rJtionl ~1IIh""riod 

"'. 88.189 114,4% 4,191 , 

Oktohoml 11,918 22,61g 1,320 

Oregan lV9l 1l,gl1 ~ Penn$'jloilnl.l 71,101 69,m '" 

RMdeltiand ,WI "" " "" m 

PIIeno RIta 17,811 l7,OO!i m " ..SOutll !:iroDn. 14,m .13.576 m 

SOutllOlkoti S,W O~ 1~ ; TtnnelM ll.3OS 31,280 U1S 

Mirfil"I$II~nd$ 10 3M ~ hll3l 141,!;4) Ilfi,141 " '''' • 

•• 10,490 10,211 

'liri"ni.l 41,J70 42,367 CO" "' ; Vlfa!n ~Inds 1;/19 1,201 " 1 

VerllKlnt un ~,~7ti l~ 

WaWrteton 41,O!1 4S,S49 em ~ WncOllIln 26,m 25,!104 ". 

WfllVlrciflii _. IS,6S0 IS,m m ~ 

'" '" , 

TOIIII 2,Il74,l'!IS 1.981,<141 11,152 " • 

NAHRO's prt$Ided _bel !# 'IOUC/Ierti~d lioo!eIio!cll is bB~ ~ ~ SUI>ey III 309 ~i II! at siUS 8I1d 

~ "'llrI<e!l; ., 46 stales ~am June I. 201Iie!/le JuIj< I I, <'()11 arttI".,pIed '" all PHk:; ., llIe cwnt.., Uta! 

8Il/IIiisIeI seetOn 8 1'OUd>tI1K"9'.I1115. Vi<itllK.el In ~ !le!tei1IageS 01 fewer houutddI iIe!VeII ~!lJte 

relied d&rent '8Ies In 1Ioe "umlJe/ CII nouse!KIIds tn8I ooJd Ile _ ill 83 perUIII ongoIrIg .orn.,i:iisI!l\iI'e ~ 

~ attOSS MIt dtr~ PItA Sores. 1lre 1l00000iorl5 3bove ilt COII5frvatiw: ~ 10 the !act IhlrlIllIhe m.e 

PHIls 

~ 

'esp!JII(I!ld 10 ~.HRO'l; _I u." ,ocerved 93 ~ admInislril!Ne lee pro-r8~ t>t!eore COIl9'ess CUI 

fees teSlDE<CfIII pro-radonl:loICY 2011 A$8 ~ PttAs' fVlanOal ~ lOabm 8J i>tIcem 

IlI1V"Il'IIIlIdfni'I;stm ... fee p!C>fllliDDO 1$ YIIl''''' 1Il.3" lIl<y IX»Id I'I! mtwn a! the bllle of ~e SOIV"y, oqd!!le 

numtlellll Iewel 00Use1lolol~ 1M)' ~ tie aDle.lO !lefYt ~V!! a lWelYe monco per\o[J V«JoI>I:I lkely be ~ as wet!. 

The 1I{j",~ &bowl "'e "i!o to/Il;_~,~ doe 10 II", lad IhII PItAS "'~ 10 "'" surveY_I .,Ired 10 !ISSIJm. 

II\aI 1Ile!! '/I00II:f be 100 ~C«f t\OuSIfIg A$!lSIIItC! PlI"'\!!lIl)IO-IaIOIIS ,aIIIBI IfIiIn " m.uillum of 9a petee11\ 

HAP p'OoiallOl'tl"'~"9 ~o .. t/If SemM!.l.pPI~ COOOlIll€oe rna~ 0<1 S~il\t!1Iber21 201 I The .. !I(Mt, 

pftAs I\tIUIr! De aIIIe 10 IIJjlpOl1 feMt f",,1ieS WIllI feweI HAP funds and WII leSS tOmlMttalM! fee '.VI':nue 

leiKfrng 10 fewe' 5!111, trOgMt C9Sf1aads, ~0II1tss .OOdIet p(OgIMI tomjlli8nce !OIl ser>icts IMn PrtAI oouk! II!'. "--'" IboIIa!!IIe ~ of !he ISO''''? 
116 

NAHRO VOUCHER ADMINISTRATIVE FEE SURVEY RESULTS 


NAlIItO VllllfhtrAd minilll1l1i" t Ftt S"n 'tr es"h~ (Jul) 14.20111 

fnnn Jun~ I, 2011 tu the jKt.'Smt. NAlIRO co!ldocled a lIIf\l!"f OIl !lK.' Impllct of 83 percent I1Hl" 

tlllJOIl'i m PilAf louchtr progtlm «IIgoln!!. admlfltStrlll\~ fee; for 201 I NAHRO's SlInl'Y results 

and ell3lYSls are Inlended 10 help lawmakers appreciate tile Imp:iOS resulting from reduced "olleher 

progJ1lm onyo<ll,g admlnl~tt:llIW reo: f\llldlllg I("wls In 2011 The .urvey wgetrd agl.'llc,es lhat, 

admimsteI OIlSII~ ChOIce \'uuchtrs (H Vs~ HUO-VClrotns Affalls SUPpor1;,t HOIlSIIl!: (1IU1)' 

VASH), Family UruflC3IIOfl Pr O~1II (FUP), Mainstream and th;;: NOD-Elderly Disabled Program 

(NED), and Di~ter HousmgAsslSl:lJICl' Pro!.'IW1 (OIlAP) A lOul of 309 public hOllSlIlgag~llClC5 

(PI1As) In 46 SUtes responded. lndoomg City, COUII!y, mull1-a)\jnry and .5tI ~""de PHAs, ~nd 

a~eJ\C1es which optr.lte in rural. subJrlxm and urOOrt areas, NAIlRO's Sl,II'\t')I f'OtllId thJllIS a duect 

result or83 percent pro-ral1011S 11\ PIlAs' OIIgomg IdmIIllSIl'llIl~e fees ror l 0t I 

l O"1'!I1 Admin Fu l'I'6-R:IIion in J6.\'ur lIi!I01"): PHAs earn ongolflS mdnUmSll1IlII'e 

foleS for each "OlIcher-lISslmd family ur.dtor lme. From FY 1004 - FY 2(110 PHAs have 

r{'Cell'ed a,'euge antlual pru-r:!!I005 of 90 perl~nt lIS COIIlpllrfld \11th the benc.hlll:lfk 11\ cft"ect 

SUlct 1998 under lite 'Quality HOlISm!) and WOll Responslblliry Ace of 19')8 " Undc'f llle 

tina! F'f 2011 Conunull1S Re.oluliOti (PL 111·]83). PHAs' IlIIgOing admlMtfllliYe fees 

Wtf~ cut by $128 "lithon or S 38 Pl'rcent compared With FY U!IO HUD esllllMlt'S Ih:lllhe 

OOSI,IInll admml5tt:ltlle fee leductlon ""ll ffSuh In 8n 83 percellt prQ-llItlOll III calend¥ 

2011 ;\s a percentltge of ;l!ogrart1 funds fOf 'CIUC/Ief IX1I1!Cljlant$, the HC" pnJglam'~ 

O!lg~lng and Special admllll!.tfllUve f~ funding 1<'Ie! 11\ FY 1011 IS only 8 38 percent ThIS 

I; lhe !owesl 011£0111& ~dmllllSlml!Ve fee pm-ra!tOll pctWlbgt III the prugrltm's Jo.year 

hlslory 

Widtst C~p in . '<'\' PnH3ljo,.s ~nd ~lilll1allfllSt-u p R/tll'll in Ilislur)': The ~~lIuge 

gap betw~ OligOlng .oJnlHlStJ1l1lve fee pro-rallOlb (83 ptfctnt) alld Ill e il.!IIonal \'OlIchl!!' 

le:l5t-up rate (n pen:entjlS the widest In the hiStory of III<: "oueller jJfogNm As ooted 

~bo.~. NAH O'~ March 2(111 survey fOlioo (!utI 87.351 fewer famlhcs will be sened In a 

12-ltl\Imh ~lIod of tune ThIs I. due to 1'llA staff 13\'011$, tile lI14blltry to fill stiff POSIIiOlIS 

that are "3calOO, staff furlOLgho Md \lOI~klad HlCreasei. In fact. NAIIRO estm\llte5 lhat 

oollonal 'ouellet leasing rales oould drop by 4 percenl - from 92 pefCdl! 10 ~pprro:lln:aldy 

88 per~t _. thmu!;h July 30, 1012 

IIII/II,~,/d Ik' rJw lorgi:.!1 droll m I'OIIt'II<'f.<J:>.$/)I,·djnlllilio 1II111~ "OOrMllltrioo (Jjlllll." '" 

/M /1(l'l!ro~l~ III.I'ory. 7"l1I~ ~(}Ij"'(lIJ(I n:/ilm UJ 111//11' !j{1(11'II1I~ fl/r:r 1m, ,,/1m Ih h' g/lef 

'" br~If/.~1 IIlrli!llll,-*1 (IINII'(}Ill1t..'r J'\l)'I~~/J I'(II~$ " 'C"" ollly ~ 1""1'('(111. 

Rrd cliGn~ in Smff alld Inerrasl'll CISl' oad~ BUI dtll ~ Will Impact ro~ AIII 

Complianct and l'trfomllU1«: NAIiRO's March 101 \ SlIf\'ty shows thaI. el'e!l wllh 

IJl(1!'2Sed HAP fUndin& prmld<.-od for III the timl FY 1011 tR. an 83 perctnt prG-IlIIi()ll lD 

~dmlm~tritll\e fee funding ",11 h~dy result In 

-;: In fJicir~ 1 SI~IT 10 Srr .. e l~ t Salllt NUIII,",. or mil;rs: Twerlly-s.. .... eII perCell! 

of PHA riSpOndt'!1U indicated I~ey h:t\"e IRSutTtclell1 staff and admllllSlllllh'e 

re5011fCe5 10 serve at leas! lhe samt nllmber of HCV holl5eholds le:;sed tn CY 201 0: 
117 


o Siaff Lllyoffs / Vacaled Positions Which Renmin Un lilled: Fifty-sIx percent of 

PHA respondents indic-ated they have latd otf sHiff or nol fill ed vacated posI tions; 

o 51.lff Fud ol1 ghs I Rtdl1 ced Work nOU l's: Thiny-five percent of PHA respondents 

tndiClued Ihey have furloughed staff and/or reduced their work hours; 

o Staff WorklOluJ ~r oll d In(1'caJes: Seventy-follr percenl or PitA respondents 

tndicaled Ihey have increased slatf\~orkloadS", 

o lligh Pelfon ners 10 Full 11110 Standard " el'rol'lner SllIIlIS: Of the 87 percent of 

rHA respondents that are "Illgh performers" under HUD's Section Elghl 

Managemenl Assessmen1 Program (Sa.-IAP), 4 1 percent of them Stile Ihal they wIll 

fall 11110 "standard performer" SEMAP status, 63 percent of!!! PI1A respondents 

state Ihat Ihey are unable to malnt.:l lll at le:1St the same level of program perfonl1ance 

and services they provided 10 voucher-assisted households and propeny owners; 

o Bc"c"c, ,, ~ Ilud Moderllte PIIA 1II1 'd il )~ 10 COlli ply with Voud ,c,' 

Regulations: Seven percent of rcsp()J}dents slated tMI they arc c.xpl'flcllcing a 

IeI'd!! hardshIp (requmng budgi'l cuts and a commensurate! reduchQn of stafT 

resources), resultmg in only beIng able 10 carry out 50-74 pcrcem of HUD-requlred 

respon~ibilities, A tot:ll of 52 percent of respondents all,< experi.:ncing s<,,.h,l/lY 

hardships, requiring blldgel cuts ilia!. \~Ollld SIgnificantly tt..--rluce resources and leave 

affected PIIAs able to carry out only 75-89 percent of required responsibilities 

ThIrty percent of PHAs stated tha t they are experiencmg a IIIO(iI!roli! hardshIp 10 

carry out only 9Q..94 perCCIlI of HUD-required respollsibiltties, Eleven percent of 

PHAs stated that they are exlX"'fIencing :I mild hardship to carry out only 95-99 

percent of HUD-requlTed responsib,lities; 

The responsibilities 10 whI ch PHAs responded III Ihe! survey lIlcJude the followlIlg. 

IS/ell'CliOIl .fro//! Ihl' Ifaftfng /iSt, 1't:!II fl.'Gsonablellf!sJ, de(<Jmn/ICIIiO/I 0/ adjllst.'!1 

IIINJ/lte, Iltill/Y a/lml'ollt:f' ,I'(:hel/ull!. 1f(III.HIli!, QIIO/II)1 SIO/ldmrl.I' (HQS) quolil), 

CO/II/vi il1Jpecliom, HQS I!ltjnfCellWI/I, eXlIlIIulmg iloll.\wg OPIXJl'ilillilies,filil'm(lrki.'1 

rem (FMU) limil. IIIld pO)7I1elll ~((mdf/lrl,I', (111/11101 /'el!xa/lli//(IIj(III~, WI'f!XI Wl/all ln.'IIf 

"tlir:/dtllioIlS, pr<'-cOIIII'llI'l HQS IIIflX!Cliol1s, {1II/lIItll HQS ill IP;:Cli{)II~, Il!a "(!-IIP~ , 

jal/lily e(f~f/! /icleIl/JY (FS:') i!l/r(I/{IIII!/11 al/d eSCll)w aCCOuntS, ml(/ dec(lnct!lIIralion: 

L'(JJllinllall(J1I q( af!pliwlI/ parl/ci' N/1II crill/Illal bl/ckgl'OlIIld SCI'i!i:/Il11g, IIIIJ/lJI(JI'mg 

il/colIIl! W/~i!lillg I'IlWiSiOIl,~, briefing.fillllilies ()II holl' 10 lIse Ihl! pmg/,(/I/I mill holl' 10 

,fllld I/lJII,llIIg, t~JI{/bli.lI/II~ <I/II) ur,t.!(/{/IIi; III<' nml T1!asvncrhf(!/I/!.I.f )'II/'l't'y, (~\'SISlil/g 

/alldlull/-It",dell/ diSpit/cS, ,'/lrO/t'fllg III.' HAP CQII/rUCI (!lid condllclillg grit'I'(!IICI! 

lIt'anllg~. Iroel.:llIl; ltect's~' (mi!, /IIill;:Olloll mil! tllldfon;roslill.!; 1'Ollelli'.1' IS,~lImlCe, 

IImill/ollllllg and /lJldalillg Ihi! adlllllllsirolll',' pia", all/lIllll /JI'ogrom IY!portillg ami 

lIIonthly ti!I/OIll n.'I!()rlillg 10 HUD, IIOI/li!l)lI'lIerslll!1 IJrograll/, program <XJIllplwllCi!, 

/l1/11d Im'i!~lig{IIIom', /lJIII rt'll,I(lI/tlbh;/If!SS .!(/fa bUSt! III"k,tes, III/lily MIt.JU'w/(,\' 

I'cltalltla re,l<'arc/I , <'II/jllnyet Iral/l/llX, land/un'! OIl/lVach. Sfli:!C:W/ aSlil:lmllce If) 

jalllilie!,' (q( ally tlllillre), /x}/'whiliIY proces,\'/IIR, /,imili-'d 1f;Jlglisll I'mjic/elley (U!.I'), 

re'/Jonah/e (lct't)lIImut/(lfIQIIS prrx:essillg, sllCe/al assiMal/('e /0 jillllifies 10 I"'OIIJ()/" 

1IIJII,I'III).i mobility illcl"dm).i hml ~illJ!, \'.:nl'ch ltl',fi,'f(/IICe ,mell III I/dp ill idemifYlIlg 

2 
118 


'1IlIIit/hh' //I'm,''IIIi; /1/ /QII'-puwr/y away or !,nil'lilm!; ImIlJ{JUI11,110/1. ,'<'mlnly dql(ml 

(IJJil'/allct {l/IdJ(Jmi~ ' or ,;redi/ IXml!$.:IIIli?, 1011 er 1II!IIIkr o!smJ! {Jdr /loIII.th,,1d (J/lJ 

pmpeny (j" I/ ~/; mul COOItIi'IO/1fI1I II'lih mlli J;:,'(!/opml!lII u.f JXlrlII;:I'.I'IIi/lJ' II'llh I{wol 

.ltin1<'1!- jl1T111&rJ "lld pliMie {jgi!IK·i~J. 

• Pili\, es rJOu ibiliri es Most Co ml)l'O llli ed : III order of rnlIgmtud~. pHAs' responsib,li1!CS 

tbat are 1I10S\ compromised include. 1) leasing up voocber households: 2) quality comrol of 

Hooslr1g Qualily Standard msptX.1ions; 3) e){parniing hous!I1g opponunities for voucher 

holdl'f~ . 4) annual rooxammations. and 5) renl reasonablcne~s. More speclfiC'lUy. FHAs' 

responsibilities thaI arc most adversely ~ffected (in order of magmlude) indudc' proyrnm 

o~erslght and quallly control, waitIng 1,51 ellglhlhlY determmatlons aud bnefings, complaint 

Inspections, annual re-exammations, and tnltlal U'Ispectlons/rent re:lSon:lblenesslle:t~e-ups, 

• EfTorts to Encouragr. FHllIily Mlf- umci~nc)' Would Be RestrAined: Thmy-s!x perce!l1 

of ri!SpondenlS said Iha! they would be unable to continue to fund the ponton ofthetr Family 

Self-SufficIency (FSS) coordlflaloris)' salary and/or benefils. In most J1Istances. these funds 

are nol completely covered under IiUD's FSS CoordJllalor Grant 

• ew~ ' I'H~ SuIT Means Fewer P\'O llle Cun Be Served: Pflor to PY 2011 spending 

roouL1ions, lIlcludlll.!! cuts 10 adnnnis!!;lU\'e fees, !,HAs adnllnl,;tenng the HeV program 

experienced an average ~nnual pro·mtlon or 90 perCCflt from CY 2004 - CY 2010. A 

NAIIRO 2009 adminlstr3uve fresurvey found thaI 32 percent of PHAs could have served 8 

percenl more families wilh available HAP and Net Restricted HAP As~et (NRA) dona~. but 

were unabk to do so because of insufficient administrative fees, 

Simply 11111. /1!1.'<!r PHA 5101lIlle(ll/,I' ji.'ll'<!r lleolne mil be sen'i:J_ HavlIlg proVided 

responsible levels of HAP and NRA III FY 2011, tht.' commil1tXl II'\I! likely fllld th:Ulhosc 

same funds will not benefit as many eltglble lOW-Income households as they otherwIse could 

tuve. Funl!er. these funds cannot L'lllT1!1111y be uuhzed to address problems caused by 

reduced administrative fee dollars andlor [Xol/lde 100 percent pro-J3tions 10 !'HAs' ongoIng 

admmlstratlve fees so that they could pn.l\'!de the staff Bnd ServICes necessnry to make full 

use of appropnated HAP and NR.o\ funds, Tbls i. a l'Ofrecrnble sUtulory flaw Ihat we 

behevecan -- and should -- be addressed III F" lOll! 

\'o llch l' Lusing in 2012: NAHRO's admmistrati\e fee SUr\cy found a projected redUCtion 

('If four percent offamihes nattllnWtde from July I, 2011 - June. 30, 2012. pHA respondents 

were asked 10 assulml thaI. for FY 2012, tht'ir agencIes would have adequate lloosmg 

A~SISlance Payment (HAP) fuodlng and Net Restricted HAP Assets (NRA I to sen-e the 

same number of households they project leasmg in CY 2011 pHA respondent> Slaled th31 

as a direCl result oflbe followingongolngadl1unistrati .. e fees pro-ra1101lS for FY 2012, they 

projC(.., ie.'lsing vsrylng percentago; of the families they served In 2011 

o 100 Pi?lccm pro-mllon '" 2.7 pereent mcreliSC in the nllmber offamilies served. 

o 95 l'erct!nl Pro-ration " 1.8 percenl merease mlbe number of families served, 

o \Xl Percent Pro-rallon = -10 perCCflI decrea~e in tbe number offamilies served, 

o 85 Percent Pro-ratlon "- -2.0 percell! decrease in the number offamilies served. 

o SO i'ercem Pro-ratIOn '" -4.0 percent decrease 111 the number offamihes served, 

) 
119 


o 75 Percent Pre>-r.l1ion - -70 percent docrease ill the number offamllics served, 

o 10 Per<:elll Pro-ration '" -s 8 p..'fCent d..'Crease in the number offamilies served 

ompl) it io n of 309 PIIA Rl'Jl pondenls 10 NAIIRO's " CV Admin. Fet Sm'n y fM of 7lllll l) 

PHA Uni! Sil.t AgffiCY Llllits (HeV. PIIA SiuAs II 

HUO- VA ~1. M~jll ll'tam , NQII-Eldfrly Pt ell1~ f of All 

Oi$llblt d Pl'ogums, Fllmil~' Unification PlIASurnr 

l't'O!!ram and OllAP Vouchfr 1'l'Oj!llIms) ReslMllldfnh 

1-99 UMS 33'~ 

100-299 unus ~' 3Q0..499 UIliIS 1m 

~·999 umls 12% 

1,0I)()..2,999 UOits ! 7'!~ 

J 000-4 om UniU J% 

~j))O,9,999 Wilts 4o~ 

10,0(';).29,999 units ~" 30,CMXI and ealerunilS ~, 

~HM ~uin!: ' 

, ~ 

'ruol 16" 

f'lfAj' Ge rn hie Sen'iceArea PUttnla e 

'"w 44% 

OOlII1IV 4<». 

mulll-CQunty 14~' 

stale ~" 

PHAs in the folloWl!lg ,!.'lIes are repre,eruoo In NAHRO's ,urvey indudnlg AL. AR. AZ. CA, CO. 

CT, FL. GA, IA.ID, IL, IN. KS, KY, LA. MA. MD. ME. ML MN. MO. MS, r.IT. NC, NO. NE, NH 

.ft~~~~~~~mm~~~~_MM~n 

,li :~Ii:.!Jli NAHR.(j 

"",_._ ... 

---

.,11-,",,: __ ,,,-OfQ....., 

6.!OI1 ,"~ ... '""'. W.....,,,,, IX.' :«KI1.J1.16(WI lj9,'Y<) 

roljf .... l(rm~l1!;~ 

~ 

... p<l.lJ~I~J 

\l !(lu ~' lIl1(o. \I~k<>: ..... 
120 

STATEMENT SUBMITTED BY DEBORAH DE SANTIS, PRESIDENT AND 

CHIEF EXECUTIVE OFFICER, CORPORATION FOR SUPPORTIVE 

HOUSING 

121 


Chairman M~nendez and Ranking Member DeMint: 

On behalf of tile Corporation for Supponive ~IOI1 si ng lCSH). I appreciate yoUr consider~lon 01 

my Sl nl~m nl in ~uppon of Congrer..~ionnl effons to refonn. improve and achieve cost 

eflkiencic~ and s3\'ing~ in BUD's Section 8 vouehi.'r program. CSIi hal long ndvocmed for 

these refonHi. as they've laken shape in various legislatin' proposnl-. including. ib~ Section 8 

Voucher Reform Act (SEVRA). We recognize thi~ hearing is coming late in the lrgislaril'c 

se~sion. bur we encourage the Suocomminee and Full Comminee to work io eame~IIO achieve 

conseMu, among ~Ukeholder,;: and pa,s meaning,ful rdonn as soon a~ po<;~ible . 

CSH b I national non-profit urg.uniz3tiun thm wodl in l'onllllUllitie.~ acrrn;.1 the cuumry 10 create 

~rrordab!e hou~il\g Jiuke<! to :;ervites thai prt'I'enl und end homeles~ne:" . Our hub omce~ art' 

localed arOl,md the country. induding. in the Chairman's home .It:lre of New Jer~ey , Supponi~e 

hou~ing is a highly ~u\:cc~~ flll and co~t-cfft'Clivc mod£:l for reducing hornele),ness. particularly 

tor famili~ 300 individuals with the greate~t bnrriers to hom,ing "ahility. 

Although lodtly' ~ hcarin! is not focusin~ on a specific legislative proposal. CSU would like to 

convey thaI the core of le1!i~lati\'e propOSall encnp>ulat~d in the different t'orm~of SEVRA 

would bring mlmy positil'e improl'emenl5 \0 the Section S program and assi~t communiries in 

their work to end homell!.' ~ncs~ thro"!!h ~upponive hOIl~!Og. TheM' COre propo~ab would 

st:lbilize the vourhtr program with 3 permnnenl funding policy. while implif~ing ~le rule.~ ahout 

how to calculate tenant renlS and meamlining the hOlbing in~peclion proce.ss. As a result. the 

I'ollther program will nUl more elTick.'l1Uy and there will be Je." unnece\Sary PlI1lt'J'\I.'ork for all 

pmi~ involved - ho~ ng. aulhQrities, tenants, and property Oll'nel1. 

Improving the Section 8 prog,ram is Critical to our work to cnd chronic homele~~lte'~. A report 

publi~hed by the National AlIia.nce to End Homeles) n~ , Slated. "Housing 1'0UChl·~:lft! 

ucces,ful in helping families ellit homele~sne~, and can protecr poor families from bttoming 

homeless, The idea that adequate amQunts of affordnble rental housing would ~ent and end 

family homel~~ sne,~ i, inruitjl·c. It is also firmly grounded in th~ r~St'3rch literature on the cau~e) 

of bOl11ele,\sne!i ~ and oT1the etTicDCY of programs that seek to end homele~ne~ for individuru 

fnmiliel," 

These pro~" providing help paying the Tent ror milJion~ of Americans of limited mean~, are 

vilally imponsm for pre"enting homele.ssne~s and foreoding it when it occur;.. In recem y<'alS 

the role of tile$C programs in reducing homele~~Ih!S~ has come 10 be, re.::ognized more broadly. a._ 

leading, Public Housing AgeT1cie$ (PHAs) have become more irwnll'ed in .\Qlullon.11O 

homele..ssne\$ m their cnmmunirie'\. 

The remninder of our ~t:Itemelit will convey our position on cenain speCific policy pT\l[KIsal> thai 

have varied in differenll'tr)ions of refoml proposals. 
122 


Projl.'Ct.Basing 5w ion 81PBV) 

PC'Opie who ~ homeless. or \\'ho are very low·income and living with physical di~abilitie.~ or 

ment~1 i!lne~~. ol1en have difficulty obtaining housing wilh a tenallt·ba~ed voucher. identifying. 

suitable apartmel1l~. negoliming telse 3greetllellt~. and competing with other voucher holde~ 

proves difficult when the."<.' populations try to L1Ii1!ze a tenant·ba:.ed voucher. rroject·~J.)ing 

solves thi~ problem by offering the rental ~ub,idy tit'\l to a unit. 

From a de\'eloplTll'm pe~pet.:til . project based voucher) ~ critical to creating supportive 

hou~ing for the homeJes~ and disabled person~ for )eV('ral rea~OI"': 

In underwriting housing for homele,s or for disahled people with Stfllit"t"S needs. 

illl'e~tor\ must know how the gap lIill be filled belWetn the tenants' very low income and 

Ihe co>t of operating the properly. Obloinin!! these vouchers cun be a "mal;e·or-hrcak'· 

faetor 10 a development proceedin,g. 

• Demonllrating that Section 8 vouchers will be project-based to a dClelopment make~ 

inve~rors mort: li ke ly 10 provide private capital ~au.e ren1al income i~ pur on >1ron~<er 

fOOl1l1g. Thi.~ reduCt,\ the IlL'fd for other taxpayer·funded public ~ublidb. 

Developing supJlOl1ive houl'ing requires u$ing.a mix of fin:lncln~ ~OUl"Cl:~ including Low 

Income Housing Tax Cred t~ . Several hou8j1\~ finance agende~. including the Illinois 

HouSIng Development AuthorilY. award e.xtra point ~ in Iheir tax credit allocation \J) 11\03<' 

developmentS utilizing project ba~ .section 8. 

It h worth noting (hat ~upporti\"e hOll~ing developments that utilile project based \eCtion 8 often 

>erve familie\ or indil'iduals who lIould be of very hi~h co~tlO the ta.\pa)er iflhey were nol 

,ta bly houled. ornele.'~ GOO low-income dilabled persons are typil'a lly un n~ured lind often 

ac\.'t'~s e~pensive public sy~ ~ including emergency room~. delO~ faci litiel, and other ~ervk1!.~ 

\J) addres~ complicated needs exacerb;1ted from lil'ing on the Slreets or in shdl£'rs: these COSl.\ can 

be avoided thanks 10 8 ,table- and supportive housing .\Clting. 

Therefore, CSll urge, Senators to preserve prOl'i,ion'l included in B December 20JO draft 

circulated ~mon~ HOU le and Senate ~taff related to proje~1-basing Section 8 vouchers including: 

Allow a PIIA to ~ an additional fjl r.llerCent of authorized IllUchers 10 stn l' 

disablt1l ur humeless PU ul~tiu s or iu urellS wrn-re l'UUl'lle rs are bard 10 lISe. A 

PHA b currently rt'witted to projt-cltlIase only 20!k of the "oucher funding. Allowing a 

PHA to provide an additional 5')' of vourher; as projel:l!lra)ed vouch~~r~ \l'ill enable them 

10 increa~e ~up]1Oni\"e hIlusin!! for (best' targeted populntion5. 

Increase Ihe lIurnbf.r uf ullils ill sma ller (lropertil.'"S Iu whith 1r pn A t"ll ll prul'ide 

IlnljecltbllSffl \"{Iueher lrssistmrce. Curren!ly. a PHA may only provide PBVs to 25q (If 

a buildin,!!.'s unitS. unless it is *",ing elderly or disabled people along with supporlive 

serl'it-es. While Ihi.l promotes incol11t' mixit\!. it can also be detrimental 10 clt"uting 

smaller affordabll' housing. deve!opmt'lm. Billlnnguageshouid aHow for IIIe greatl'r of 

25% of alllJnits or 25 total unit'! pc.~r devdopmem to be project[1lased. Modifying thil. 

rewiction will make it easier to develop arf(lrdable rental units in rural nnd suburb:U1 

mrnmunitie.,. 

, 
123 


Enablt'll "IIA to IIrOI'idt' additionnl projcct-based I'ouehers 10 properlies in light 

renlal markels. In cenain rental market~ acros~ t~ CQUntry. the demand for rentsl 

housing h3~ grolm rapidly. Por everyone unitClf 31'llilable affordable rental hOll~ing. 

there nrc three fatniE~ wailing, Allowing ft PIIA in the\t' type~ of rental tl\3rket~ to 

I)TOVide a"j!Jlllhl.'e \0 4O'k of dwelling unit) in a building. will not only inrreJse the 

3upply of JffOrd.1bk remlllllOu~ing in these I1gh[ markeh. but .:I.lso mak!' the housing 

development more 11n8llCia!ly feasible. 

Permitting owner-nmnagl'tl, sile-based wailing lists. This provision would ~ helpful 

in ~upportive hou~ing and other ,pecial need~ hou~ing becau'\e- it would allow the own!'r 

to affirm:J.th'ely m.:lrket to Ihe de,lired disabled population that may be required by other 

>ill> ice doll~rs in the mix. BecauS<." some Housing Agencie~ ,creen out certain hard·lOserve poPulation ~. il w(ItJld make il ~a~ier for the ownCf!i 10 ''\creen in," We also believe 

owntr·mnnagcd waiting lists have !he p(Helllin\ to reduct the lime tha! ~ unil remnin~ 

vacant in between lenants. 

Ease adminislra!il-e burdens on deleloJlnten! initiatiH'S ror PIIAs.ln C.1'ie~ where 

CQnl'en.ion Qnd redevelopment of public hOll~jng i~ authorized and overseen by HUD. 

PHA~ tlOuld not hal'e 10 go through additional burdensome oominiSlt:ltive 'Ieps to 

J)TO~I·ba e the replacement voochell they are awarded by HUD. Providing thi~ liinited 

e~emption will enoble n PHA to move forward on a redevelOP!ntnt initiative and 

prc.\trve former pubHc hOll~ing properties wilhout any unne<:e~,ary administrative delays, 

Modify how a PIIA allocates projrcl-based \'ouchers. CufTt'nllaw enables a PHA 10 

provide 109, of their vOllCher funding to 3 projecttbased voucher progr!l!1. Each PHA is 

autlloriU'd 3 'let number of vouchers it can provide to the community. Changing the 

limitation to tJe ba:-ed on authorized VI)Udlers in'itell.d of funding will make it easier for a 

PHA and HUD to tnlck. facili tating over:sight of the program. 

Cilirify th:lt owner.! of multifamily properties may ('I'ictten:lnls only for se rious 

l'iol3tion5 of lerms of leaS(' or violations of apJllicabie low. Current law ~n.1ble~ nn 

OImer 10 ('''lela lena11l in a PBV ullil without cau,e at cootract renewal . whko will 

uhim;nely rtduc~ the proj{'C (lI~o;ed Nistance available to 10wIJncome families. This 

chtlng~ will ensure thnt an eligible fnmilycurrently receiving assislance will conlinue 10 

rcceil'e asshtance and not at the di;;cretion [If 3 multifamily owner. Muhifnmily ownen; 

will ~till be able [0 enforce lea~e lenTIl and utJlizc Tt'medie~ aI-rulable [0 them if a lenant 

is in violation of Ihe lea~, Thi~ ~ the ~al11e JXllicy ~lal npplie ~ to oll-nen. of multifamily 

properti~ n~si"ed by ooe of HUD' ~ older section S progrnrns. 

~e changes 10 the POV program will help illCrease the supply of affordable rentnl housing, 

provide ,upponive housing for vulnerable populmion~ and ~treamline adminhlrative processe~ 

for PHA,. 

Minimum Rent and IInrdshi,) r. '~ li Il 

CSII ami many of our panners have conveyed to Congre'i~ and the Adminiqratjou our oppo ilioo 

to proposal, to increu-e minimum renll>. particularly in the context of an imponanl demo.graphie 

trend over the pa,t several yean.; 3 pronounced increase in the number of eX\f('mely poor 

familie~ with nO in(:()me from governmenl bendit~ . ~nd no Of vf:r'j liule incolTll' from 

~mploYl1"lem . This tfend. largely the result of high r:lte ~ of tJneml)lo~rm'nt althe bottol11 of the 

labor ma!i;el and chungt!> in fedeT3!. .tate nod local government ~upport for low-inCQme people. 

J 
124 


ha~ contributed to increase~ in the numbt!r of people in "deep poI'eny," i.t. I~ith incOlI\e~ les~ 

than half the federnl poverty level. TIle.~e a/l' the fami!ie~ thai are mo~t likely to become 

homele,s without ,uMidized hotlling. Many face mUltIple I>mi~f'!j to employmem, 

One propo~al in the Hou$t of ep~entnli ve:. would rnbe th(' allowable minimum rent from $50 

ptr lOomh to $75 or 12 perCfllt of the applicable faif market rent whichel'er i, higher, Twelve 

percent of FMR will be high~r for most familie.', induding th~ in lit lea,t the high. rem areas of 

every ~tatt. For ~1(ample. alluwable minimum rent in Orange COUnlY. CA for a tW(j·bt!droom 

apanmelltwould he S198: in the Bronx, 5171: in Charlonesvilk, VA, $123: III Birmingham, AL. 

S9O. 

Current bw, uf CUUI}(:, uJre:llly uJJow~ PHA\!O fl)tublish minimum ren\.) of up tU $50, nnd mo.'t 

have. l1lU~ tile idea that "everyon~ "hould pay something" has already been entrench<'<llll 

fcdcral13w and local PHA practice. TIle ni.lting policy atfetts household~ with Lhfo loweSt 

income, Il'ho under normal rent·~ning rule, would h:we ~ renUlI and utility obligation (~enerally 

30 percentof income) of le~) th~n $50: I.e, hou~bokh with income le~~ than $167 per mOllth, 

ror thi: 10wC.lt·incOlU(> people ",110 are unabk to find work. tit.: obligation to p~y minimum rent 

can leave them dependent un violent relation~hips or exploitll'e economic Imnsaction\, In the 

current job market, tho~e with the lea,t competitive re.>,umes afe unlikely 10 find other ~iable 

option.\.. 

Under Ihe governit~ statute, A~ and landlord~ are suppo~ed to recognize "hard,hip 

~xemption~" from minimum rent polide" 'fhtre ure nn ,\tondards for requiring. PHA~ \U 

coherently explain hard~hip exemptions to tenant~ who may have cognitil'e or p,ychiatric 

di~3bilitle~ or .-evert educational deficib, or for milking sure that e.'ptanations are given at a 

relevant time. Arlecdotal reports from the field and the one aVAilable HUD ~tudy 

(w\\ w,hudll)cr.nrt/puhlic3tionvOOf/Rent<l20Stu(lv Final'1,20RepOrl 05·2()·lO,!ldO indicate that 

vtry few tenant, receiw hardship exemptio ~, 

In ~ome ca~('~. minimum rent~ WOUld be doubled. tripled, quadJ1lpled or more. The impnt! 

would be an economic burden on the \'ery poore:;t households. Wbile the amount'i may seem 

trivial to ~ople with prol'e,~ional ~lnries. for j)eQp!e sIJ1lj!glin~ to ~urvive and fetd their 

children with sporadic low.wage employment. an increase 01 S25, $~O, $100 ur $150 per month 

can make the dilference between hou,ing !lbbility and eviction, People evkttd from assisted 

hou~in~ are known 10 be at extremely high risk of immediate home\e:s~ness. 

While we encourage the Committee to reject proposals 10 intTea~e minimum rent. ~hould il mid 

tile provision necc$sary it is critical dUll corre~ponding prol'i~ion s he included to improve how 

tenants can ~ucce~~fu\ly apply for 3 hard~hip txemption, As a .\Ulrter. any fltmit) thall~ exiting 

homele,~ should have a pfe.lumption of hard,hip: the agency will ~Iill surely review the tenant'~ 

finance,l, ho\\'el'er we btliel'e, hardship should be pre~ulTled. Funher, Ihere should be an 

affirmathe burden placed on the PHA to demon~tr:lte the adVertisement and al'ailability of the 

nemption is made known and available 10 any alld all familie~ who may be subject to minimum 

rem paymentS. 
125 


Sponsor.basing Section tI 

We a!~o encuurage the Committee to ..... ork with Hun nnd other Stakeholders and include 

authorizution for tI A~ to ~ponw·ba',C Section ~ ,",ooehm for the purpo~s of combinillg 

hou ~mg and supportive M:rvice.~ for highly vulnerable homeler..~ individual, and familie~, Thi~ 

proposul. v.hich was outlined in the Prc<:ident's FYI3 Hun budget requcst, would provid~ ~n 

imponant new tool for A~ to help ~nd homd~!ines~, i\dvocat~) and Hun have bi.'t-n in 

contac~ ,iroce rekaw of the Budg~t reque~t and while we ha\'e some ~ugge~tions of hqw to revi'>\'-

thee~act lang.uag~, w~ Ix!liew_ h~ Committee ,hould work to nchi~\'e con>en~u~ and include the 

prop(hal in s reform hn!. 

Currt'mly Section 8 rental a)sistance is tied either to lhe tenant (tt'nant-based) or to a ~ilic 

hou1ing unit or buildin:; (proj~t-ba~l. [n a SVOl1so[-ba)t'(\ pro!!ram, a non-Jlrofil urganizlltiun 

that worli:~ with hnmele~.\ people in tht' communIty lU1d help~ them aCC~I) crucial .lUpponive 

~ervices holds the vow::her and is able to eilher lea~ a unit on behalf of the tenant or worli: 

directly '.I-ill1 them and the landlord to help t:1Ciliute lease-up, 

The Section 8 Rental A}sistancc pro~am is IUD·~ lar!c-st affordlbk housing progn::lln arxl 

provide.>. critical rem a~sistance to low aoo extremely low-income famiJie.., aod individllnl~, 

However. fOf the rea..'ons described btlow, in rno~t cornmunitie~ a C<;lh(ln of highly vulnerable 

homele~~ people are often excluded from being able to acce"" thi~ ~uc~."sflll pragmlll. A 

~pon~or-ba.'it'd program add~ another tool 10 the toolkit for how 3 PHA can help sene famihes 

who might benefil (rom supponive servke,~, In out judgment. a property de'>iglled ~pon,otbased progr:trn con offer a greater level of !lCcmcibility and cOOkt' for fonnerly homelo.> than 

the tenant-bao;ed program. 

The Seetion 8 appiic;Uion and renlal pl\X.'l!'~ is tspecially difficult for people who are 

homeless with poor rent hiMorie~ and who !1la~ h:tve a di~ability, 

Housing .Icarch cun be e~]ledal1~ dimclllt for the..,e populations, Landlords are often 

rclucLlnt to rent to people with poor rcnlal hi~torie.\ , criminal b3tkground~. or who 

otherwiSt do nOi pre~~nr well when applyllJg to lea~e 3 unit. IndividualS with no rental 

hiMoriM, such as lho~ exitin~ il1stitutiom or group home sitllJtion. face ~imilnr barriers 

in using a Section 8 voucher. Thi~ fact Cdn m!Lke an otherwi>t valuable voucher 

efflXti~ely \\'on~less for some people experiencing homele~SIIess, 

Waiting li~b for a ten~nl-ba~ voucher are very long in mo~t communitie~. While this b 

n problem for all those in need of n voucher, hOl1lele)~ people are especinlly tr3n.,iem and 

\'ulncrabtr and cnn be difficult to IOCJte hould a "oL!C~r become a\'~ilable 10 them. 

PHAs rarely han· the re\OulteS \IJ locate a pt'f'Mln if they don't ~pond to an initial 

mniling or lephone call. 

A key goal of the ~pon~{lf-basing program I~ 10 affim13tively )creen-in to the Section 8 program 

tho~ homeles~ inllividuab \Vith service necd~ who woukllikety not otberwi-.e pas~ Section 8 

and/or landlord scr~tning in the community. Sponsor-based rental s))i,tance should be dc,igned 

to lower tile barrier to entry for homele ~ people who have many challenges acces~in! ,table 

how.ing. including more quickly mOl'ing ~omeone il1lo n unit and not have them langlli,h on the 

stIeet or shelter while adminiMr.uive work b completed, Spon,or-ba~ing aho effectively 

addreN·S the key barrier de~cribed abO\e that many landlord\ will refll~ to rent to persons ",ho 

; 
126 


do not pre.o;ent them~elve~ a.' lTlooe len ~nt" or who have had difficult rental h~torie~. In thi~ 

ca:-e the Sponsor ai..~ulUe., primary responsibility for the unit and lease compliance, and 

encourages more landlord.1 to rem their \lnit~ to JlI.'Ople lI·ho they mherwise mi~hl nol rent to. 

This provide~ peopk in~oll ed in tlle program with greater hou~in~ choice. and Creal '5 a 

lnt'Ch3nism f!,)l' ,\,('Curing ttddilionnl housin~ option. in the el'enllhe panicipanl does not like or 

have issue~ in a panicular unit or building. In uddiiion, we believe the quality of ~ervic~ may re 

improved a~ the Spon.'iOr ha~ n I'e.lled intere_t in the resident\ ~uccr~s. Grrater accountability 

ror the servic~ provider may al~o ea.,e concem~ oflhe Homing AUlhority 10 enpge with hard "to-

~r\'e rKlPUlllliolt',. 

Spomor·ba~in,g renUlI nssGtance i.I: not new. anIJ tl ~ President's propo~31 recognizes lile existing. 

rtTective use uf lhi~ lype of 1I~~iMance. Sponwr·based rental a~~i)tance to help hUll-'e hUIlIe!e\s 

individuals and families hal been II popular and effective u~e of funds throug!1 the cKinneyVellto progr.1l11 (Ipecifically via the Sheller Plus Care program) for m3lly y<,m. In lhl' 1010 

McKinlleY rompelition alone HUD a'Narded over $25 million to 71 project~ using ~polt~or·ba~ed 

a,si,<,tance. Moreo\rr. many PHAs adminbter Iheir communilY-.1 StC award. indicating that 

nntural capacity may c'~~1 for IA~ [0 take lhb program to !O:alc. 

AtlellSt four A~ with Moving to Work (MTW) stntus - which gives the PHA re,gulatory 

f1e.\ihility - have been particularly innovalivr in improving. :l(.'(.'t!S.\ to lhe seclion 8 ~lIlal 

mi.'lance program for people with hi;torie~ of homelrt,ne~§. In addition to providing 3 Section 

8 voucher to a family or 3uaching it to a pm[ll!rty a~ in lhe Pro,i«t B~sed program, these !'IMs 

llsed lheir MTW stant~ 10 flex ibly add the tool of sponsor·b.a~jng a ,mall percemage of vouthen; 

for high·need homeless people. In doing , they are building off of years of e~perie1lCe with the 

McKiullcy.vemo StC progr.un. which has succe~sfully IlSt!d .'pomur.ba.,ed rent.1l as~i;'[aJlce. 

The mo.t promillent fealllrl' of 3 )pon~r·ba.led Section 8 voucher i$ il.'> illhertmt imegration of 

remal a.\l,iStancr with .llIpponive !lCrvil't:s 10 help the resident Mnbilil(" in hou.ling and thrive in 

the community. The cotnbill2!ion ofaffordable hou.\ing with fiexible. consumer·oriented service 

tklivery has been pro\'ellto be a highly effective tool in eflding. ho[nd ..... >!le:>~ and improving the 

live._ of hjghly vulnerable iJtople. 

CSH lIould greally 3ppreciate the opportunity to di!>ClJ.\~ the! ~pon,or·ha.~ing propo~al further 

wilh Members oflhr Committee. 

In conclusion. we agaillthallk the Subcommittee for calling thi> hearin2: on Section 8 reform 

proposals ml{! strongly urge you to move forward with :t legislative proprual that illcre:tses 

efflciellcy. lowers barriers to hoosing, lUId bring.s the wonderful yet scarce Section S re~ource 10 

more familie, in need. 

(. 
127 

STATEMENT SUBMITTED BY KRISTINA COOK, CAE, ON BEHALF OF 

THE NATIONAL AFFORDABLE HOUSING MANAGEMENT ASSOCIATION 


NAHMA 

TIOUl H IOIOAtU KOUII~G M.UGUlin !IOtl lI0 ~ 

Written Statement of Kristina Cook, CAE, 

4OO_Cd .... ~ 

.. ,,'" ~VAmt' 

(703)5U8O.Xl 

I7OlI~FAA 

Senate Banking, Housing, and Urban Affairs Subcommittee on Housing, Transportation, 

and Community Development 

"Streamlining and Slrengthening HUO's Rental Housing Assistance Programs" 

August 1, 2012 

TharoII you, Chai'man ..,~ a1(I Rar'Nll M$'nbilr De\4lnt for perrriIting me to sutmt tis statemenl. 00 

behat! of the National Affor(lable ~ M~ Assooatioo {NAHMA}. NAHMA is a roo.pro/it trade 

assooation I!'IaI ~s J11.J1tifamIY prnpEf\y ~ .r.CI ~....nose It1ISSIOO ts to ptO\IIde qJality 

aIIordaDIe rental hrusng NAHMA is also Ih!i VOICe I'll,.\la s~ lor 20 fego'lal affordable hruslIIg 

lI1a1<IQemef'II assooaIioos ~ 

NAHMA S1rOIlgIy st.ppOIIS HUO's rentallD..istng 8SSISIOOCe progams, panicuIa1y !he Section 8 HouStllQ 

CflOI<':e VClll:'tW (HCV) M:! It'Ie flI'qect-BasEod SeeIIOO 8 pmIJIams. The HCV 1$ a Ylfsatije program !hat haps 

stabiMze toe WH 01 rmm CIf ~s by prwiding Ihem access ttl albdaille houMg 0/ IhBIf cMK:e. The 

Prqect·Based ~ 8 program provides safe, dean, and atroroabIe houS<ng 10 America's rTI06Il'\IterabIe 

hous9/lOIdS, Marr,- 01 tIese properues also p-oYide critical services lc Ileir resldMts, !he ma,ooly cI \\1'ich are 

ei(t)et eIde!I~ or disaIled O\IeraU, t1ese provams on etamples 01 sta:essfIA ~tjo.piV8te pa,Tpershps 

NAHMA looks forwafd to ~ 'MIn !his S.iIcommIttee to make II.IIroer i~ ttIa(""" snamln! 

and strEnglheo toe f1CV ard Projed-Based SeaIoo 8 P"lQfam5. 

To IhaI. end, we lXge!he SIb:ommntae to move !award \\iih SecIioo a re/oon 1egtsIatIon. NAHMA stroogI)o 

s\WOI'IS a rumber 01 reIom'ls i:I HUO's rer1ll! a~ progrc!rns IIlaI Yo1!re inCkXIed In toe Q5(;\l!.S!Or1 tlraft 

01 toe AffctoabIe Houst\g aoo Setf ~ I~eme!t ACI 012012 {AtlSSIAI as passed by tte HOOSe 

f'mnoal Se'ltceS ios..-aro! HOMlg, and Corm'tI.rity ~ Sutxxmnillee tJ1 FetAlay 7, 2012,IThe 

same provISions are .no Iou)d 111 a later A.M 13 AHSSIA Ameoctoert in the Nalure o! a &bs~~te l vh:h 

was ~ to be ~ <Ulng t)EllUi flflllnQaj SerVICeS COnmrtIee maJt.\4l t.1olf?i of ~ cI\iIf!Qes 

I" CO!7Y ot the AHSSlll IJiII pa~ oy til!' HO~>tI SIlbco1TJlI;Uee 90 FelJ\l3ly 7, 2012 IS a~arlaDie at: 

!l!!DJ/lioanQalsrolces house Qo'!!'\!p!oadedfJrslBILlS· t 12!Jr-PIH·AHMg WI 

' The 1egISiaiMlIeJCI oIl/le Amendmelll '" 11M! ~alufll. of a Subsl~tlle 15 IY<lilatJie at. 

I\!tp'llIo'WYI nahma ol!!lleg'l.20~real(l4-12-1l!@AHA'I(,20S"bSt~lJt~ Pt!f 
128 


\WIJId make \he HCV and project-ba5ed Sedion 8 pr'Og(afI\S ~ user..friend!y fer rertal hou~ froYM. 

wren! reSidents, and appiicants (or assiswce. 

My statement v.illocus on the most ir"nporta1t reforms to NAHMA's ~~ managers and ~ proposed 

111 !heApiiI13AHSSIA &ilmJte AmerOmenl 

Inspection of Owelling Units 

The -streamlined flSpection process prop:lsed in Section 101 cA AHSSiA would remo\'e a majOr 00513de fcr 

voucher hoklers 11"1 \911 rentaj nwkeIs Be/o(e a SectJOn 8 VOoJCher I'ddef can rent a spedlic apartment, the 

oomriSlenng agency Il'llSI fu'sl1Ospecl the LJVI IO cooIiJm !hal k COO1p1ies wotl HUo.presaibed Hoosrrg 

Quality Stirdards (HOS) The resottir!g delays 11'1 tease-ops cause apal'lmeots to reI)13II1 vacant. The lina/lCIal 

10'IpIlca/l0rIs 01 such del.!lys ¥e eno..ifI1 to 001« I'11III'1) 0'I'WfIeF'S from ~ io tie program, e~y in 

IoN-vacancy markets 

The bII proposes corrvnor;..sense reforms (Q the ilspection reqwemeots IIlat will he\jl !)[pedite the lea~ 

process for I'Ol.d'Ier 1lOiden;. These cllariges have Ie<:eived bpaftlSar) arC If\(fUStry support. In paOOJIar. 

NAHMA strorQIY supports If\Spedjoo reforms ~ \YCIIJd 

f'em1It housing agenoes to approVe leas~ in properties I'r1lId1 passed iospedioos '-'1der a program 

I'Mh slandafds as leas! as sfrIrgem as t.e HOS, sudl as !he HOME or !he lcm Income Hous~ T lU 

Credit (UHTC) program: 

Streamln ng tI\Is Pf'(lCI:lSS IYiI prO\'llJe Ih8 re5!dentS With m~ needed rt:lUSing SOQ)ef, en5lR a.o.ners 

n not losrIg iooome dt.e to delayed i"OO'I~ aod ero.Ji.fages otherOMlefS to parocipate in \he 

""""'" Moreover, ttis reform .,..;)I help the vru::hef progran wc:w1I better with O!her fedel'al rental assIStance 

l)"O!1ams; 

o AHl1NffiII'lOI"repars 10 be madeafterthe lenant moves inIolheapartmeot: and 

o Grie P'bIIC: /'OJSIfl;l ageroes (PHAsI1tle Q'sctetKln to "Inspect uriIs oo:IJI)ed by vru::ner holders every 

ottw '/Mr, rat/le( lI'Iao ~y lor the term 01 the HAP CCfI\ract, 

Rent Reform and Income Reviews 

NAHMA has been espeoany ~e d prtMsions t. Section 102 cA AHSSIA ...midI would replace !he 

<I'lfllaIi"1cqne certlK:.aOOn r~rement lor families 00 fiXed R:omes I'Iilh a reqlIremenllo revIEW !her" 

1I1COfTIe5 at least ooce every nee yean, we ~e thiS c:h~ \WI greally aSSIst ~ aoo disabled 

PROTECTiNG T'rlE INTERESTS OF AfFORCABlf HOUSING PRCPfRTY MANAGERS AND DW'IERS 2 
129 


househoIdsl'Alose II'ICOOIe and swc.es of income do 001 vary Il1\X:h from ear·lo-yelll II will also redu;e the 

adiMstrative ~s 00 prqJefty aM"efS, m<mgement 1IQ€Ills, and tenoots of the Hev program. 

Targeting Assistance Itllow·lncome Wor1tihg Famities 

NAHMA Sl.WlftS the d'Ia~ In $edlon 104 of AHSSIA I'ttjct) \WI alloW ~ a')d PHAs to expn thetr 

Income tar~ lor puI)1ic housir'9, voudIers. ilI1d based Section a assis!a!J::e. ThIs chalge wi help 

IlDu!.e families ....,11 IncomeS thai do not exceed Ihe higher r:I #Ie poverty ~ne or 30 percent 0/ area median 

"""" 

PHA Project..flased Ass1stance 

Prqect-ba51Sd ~ (P6V) are an II'npo!Wll tool i(l expandng !he ~ r:I affOl"Oaoble heming, parllwlart)-

wt.en used with the tax aOOil pro;,m11 These vo.xtoers !!low 0M"\ef5 to b!ild aIIordabilitj lnlo rer properties. 

SecIton 100 of AHS5jA exterKls the IT\aXIfIlIJ'lI aIIowaO~ t\Qusmg aSSIstance payment (HAP) tonrac! term 

Detween the PtIA. and C7"NI1ef from 1510 20 years. In CO'"~' e~,leoo:JefS prefer 2().year rental 

as!.iM1ce oonllads to sho!t·term 00"lImds. NAHMA suppats II11s dl.rge because we belIeVe n MI help 

developerS to secure more favor~e ~U1:I terms and slrear!Jlijne the use 01 PBVs v.ilh other" federal 

I10UsIng progams. ~udirlg the UHTC. 

Establishment of Fair Market Rent 

In preVIOUS Section a rew eflorts, HUD sought 10 eliminate thestalOtorr requlI'em.enl to poJbHsh Fair 

Mar1\et Rems (FMRs) on October 1 NAHMA is pleased thai Section of 107 of AHSSIA preserve! this 

mandate, and it ensures 1M! Interested sta~eholders and members-olthe public wig cootlnue to ha~e a 

meaningful opportulity to comment 00 FMRs. 

Refit Supplement and Rental Assistanet! Program Contract COflversloos 

The ~1dat2d aod FIJ'1he( Con~(JJng Appropf1B~ons AClof 2012 (P, L , 12-55, H.R· 2112) 9(a!1!el1 HUO 

au1hai1y to c.oncItx:t a R8f1ta1 AsSistoo:e Oemonstra/loo (RAO) program. The pJrpOse of the RAO Is to test the 

feasibilily of a~ at e capital to piesefVe propertIeS as5isted under HUO's ~ ~ modera'.e 

renabiltabon, Rent Su~ (Rent&w) and Rental As~stance Payment (RAP) programs. The kej to 

attracIIng toe private capiIaj Is ronverfir'9 the rurreot rental assistance on these properties 10 Iong.tenn 

projed·based Secbon 8 caMICIS. NAHMA remains 'Ier'f interested in the RAO pruviSlalS wt1cti allow owners 

PROTECTING T'rlE INTERESTS OF AFFORDASLE HOUS1NG PROPERlY MANAGERS AND O/"d>lERS 3 
130 


ct RAP and Rert Supp properties to coo ert their ten<Jll proteaIon vwc:hefS to projed--based rousing ctlOice 

vouctIefs unOOr certIin _ 

Sectior1202 of AHSSiA bulds on RAD's pteseNaIIOn opbOOs for 0MIefS of Rent Supp iod RAP prope1ies. 11 

authoozes HUO to corwen elOs~ng Rent Supp anti RAP contracts 10 Section 8 project-based rental 

assistance contracts. subject to the terms of section 524 of the Multifamily Assisted Housing Reform and 

Affordatiility Ad of 1997(MAHRAA) 11 also directs HUO 10 treat the resuitlflg centrads as renewals, af1(l 

authonzes appropnabons to complele the corwersiorlS 

NAHMA supports Ihese new !ods to ptesetVe and rn~ta;n !he affordaIllity of RAP and Reo! &.w propBI1Ies 

Access to HUO Programs for Persons with Umiled El"iglish Proficiency (LEP) 

Tille \II O! Vte CMI RIgnts ArJ. prOOi!).ts 3S01mU'lation based on I'labOrlaI OOQlll. as well as poIiiaes or acoons 

M'ictl have the effect cil1Jl,dtjQng eI~ foretgn-bom IndivldUas torn partidpat~ in Iederai pr'Og(alls. The 

Federal Govem'Tlenfs positIOI1 (artK:ulaled by the Exeo.Jti.ie Brardl) since August 0/ 2()l) has been thai LEP 

obIiga !)1S e~st for ageoaes and reciplents of tede'3i fuJ'lCling IJI"tde( Title Vl 01 the Grii Rigl'lts Act. Therefore, 

fa ~Ufe to bidge t1e OJmI11!nCaboo barrierlor a person IWh LEP may be dscnrnlnation based on r.ational 

origifll.f1Oef Tille Vl, because ~ ~nguage larer results from the pef500'S natioroaj or9n 

HUO's LEP IIIJIdaIU became efredive on Marth 7, 2007 It staleS that rea~ts of HUO Iurodiog, ioduding 

afftJdable rental hoUS!flg Pf'O'>'icIEn hal'll an 00I/gab0fl to prtlVJde translated doo.Inents and oral inleqlfetation 

ser'llC2S to persons I'AIo hal'$ diffialty COfOI'I'IUIicaIing and readtng In Itle English Iarlguage, Ongina/ly. HUO 

ptO'/!ded f10 ~ fl.ofug fof reopiems to offset Ihe costs 0/ proOOOg language services. Anothermapr 

CQ"'I:':e01 WltI\ 1I'IE! ~ was HUO'S faIlUre 10 klenbly a specific lISt of OOCI.ments hOUSlI"Ig I:tOVKIers WOUd 

be expected to rranslals. Affordable housing provXlers estimated \l'lIl'lSlation casts to cornpIi 'MIh It\e 

obligations described fl the gJIdance IXlIJkl exceed SI0,OOO pef language per property They also argued 

such costs coJd divert preoous ILods m m3inler.ance and opaations, v.tIidl would )eOpiIl'IflZe tile rederaI 

InVestment i'1 HUD-aSSiSled~. 

tJr, Chairman, !hanks in ~ pa(l1O 'PI ~ade!'sIip on thiS Issue, housll"lg authOrlzers II1d appropnalO(S 

recogl!Zed 1ha1 the Widespread duplk:atia] of effort 10 !reate the same ~ts across properties would 

resuH in ira:osisler1 ~ity fi service to LEP persons To er\Slre lmited federal ftnIs \Wre used most 

effioently Congress p!O't'l(Ied HUO With modest WOPriations to create translate(! matetlals a.ld other 

programs 10 assist LEP persons. HUn's translations a-e posted fD ils Fair Housing on:! Equal ClpportIriIy 

""'-

PROlRTiNG T'rlE INTERESTS OF AfFORCABLf HOUSING PRCPfRTY MANAGERS AND QWIIERS 4 
131 


As approprialiOOs become ioo'eamgly ~Jted, ~ IS esseo!lal to aJIhorize a lEP tedncaI asSIstance progran 

'MttWI HUD, WItoJ. continued IederiJI support, I"., fIna1daI obIigatJoolo pa) b" !he Ial!gtJage 5el"t'K::eS wijlla" 

solely 00 HUD-assisted ~mes, p!.b~ tousiN;j agerdes and oIher HUD recipients. Mr Chaimlan. in toe 

111lh Congress, )'QJ invodooed ~sIatJof1lo address ~ vI!!)' Issues S. 2018 was a bill 10 aMCM' HUD 10 

better serve persoos WIth irrnted EngIi>h proIK:Iency b'1 pra{ldlng tec:tnc.al a:;~slBEI to reCIpier1ls d Fedefal 

Mlds, Section 501 of AHSSIA IOdlJdes man~ of the same ideas folXld in S, 2018, iMl~e lhere are some 

dj/ferences in the legislative language of toe bills. some common eiemef11s woujd; 

0) Create a task Iorce or InOOSuy and O'IU J';;;h!l; staKe/'dde(s to Identify I'itat documefIts (to ;nd!.de boIh 

oIfIdaI HUD bms -and ~ property documents); 

J ReqUre HUD 10 translate the .,.;~ documents withm six months; aod 

CI Aumrize a HUo.adrTunistered teIeohooe hotIine 10 assist 'MltliT.llllfl'.e-prelatial needs. 

ThIs approach represents an e/ficlent O'Ieraliuse of limrted federal hoUsing dollars. 11 enslXes 

mearllngful access to HUD's houSl~ programs for eligible persoos WI1tl LEI'. At the same lIme, ~ afso 

relieves houSing operators of a cosUy unfunded obiigabOO, al'ld il olfers a higllef-Ievet 01 quajity contJ'oj 

Oller the services prO'lided to LEP persons. As a reslJI, we strongty 8f1CO!¥lIge the SlJbcommftlee to 

Include language authorizing an LEI' technicat aSSIstance program as pan 01 an~ alfllrdablehoosing 

refonn IegislalIOO. 

Conclusion 

NAHMA srongly suppMS c:cwnmm-sense reforms 10 IITIpIOI'e the ebocy of Secboo 8 proQI'lWl1S and 10 

reduce ~rating costs for nouSirQ prowlers My statement oestI1beS toe reforms ~ are most I/Tlpatall to 

NAHMA members. Q1 behalf ct NAHMA, I resoedfut./l¥Qe g,js Subccm'l1i~ to move forward >MIh Secttoo 

8 reIoon /eglslaIior1lo1ward lhal lndudes these ~ons 

In addllKln, NAHMA encourages the Subcommittee to be mindrul aI' <¥rJ poIrial mristrative andior cost 

tudens that a Section 8 reform bill coUd impose 0f1 OOusing prOYlders. These types ct mandates Oefeat the 

goals d Secttoo 6 reform, arKIltley SI'ICUd nrx y,tInen Il'\1O ieglSIaIJOfl. 

Thank you again lor !he opportunity 10 comment on proposals to streamline and strengthen HUD's rental 

assistance programs NAHMA looks [OIWard to woOOng wltn tOe SubcommlUee to impro~e these 

programs 

PROTECTiNG T'rlE INTERESTS OF AFFORDABlf HOUSING PROPERTY MANAGERS AND QWIIERS 
132 

MEMORANDUM: PROPOSED REGULATORY AND ADMINISTRATIVE 

REFORMS AND STATUTORY LANGUAGE 


To: OfI"u ofPublio;:>oo [OOM ~ U.s. DepIrtrmI ~!iousi-c and Urban DMllpmm 

Film NaOOnaI M.o;Jcilli;>n ~lIoll"lnd ~ Otr",iah 

~ Y.!4IlI11 

k: ~ Rtpllloryond AdmiIistnIil"t Rtbms and SulIIOI)' ~ 

Con;rns IIlSltd major ",fuml$lG Lhe Secliln S HoItsing Choic~ Voudlrf prognm (He\,) in 

[991l11L<Xr lhe Qual~y HOIIJn, Work and Re5jIOlISibiliy Al;l (QII\\'RA~ TIlt III:t ~1II deligroed 

to ci-~ Jlllblic OOIosq Iitfl"ies (PHAs) lhe muirrum f~1t U>:)UII: ofl!Ah:riy. dOOtl"" 

ond rorwL pam wib In IIppAIrialc Itvr[ of It"COIIUbiIity 10 rt$iXlIS, kJQ[iies .m m. 

cencnl JIIIbb;. NAHRO br[ir>~ NI iI illID"li!x iIr HUD to build QG lk IUttHSft IIthiel'fll 

IM>us/I QlIV.llA. 

Houle repan ~ ~ .. m. FY 2006 HUD tpp"OpriatioN bill d~~ HUD to 

)I"O\·idt ~ "'ilI I I;' of .iniltMi>~ and ~.ory ~ LlIII «l<Il:i be puL .. placo: 

.. finx to btnrft PHAs b 200i. Undet House Rtp.lll 109--[1), m. House ApJroprialilns 

Commilltf "direa[ed]lbe Oepart~nl.to lake Whlrt,",r rtgulllory &nd adminillr1li'~ KIm i 

can to inmasc fluibil i y, redUCt admiol !lrll;'~ buriItn and !lrtamlint program 

iJr4)ltmcnl.ali.m. ~ Thr Commit« d~ IIUD "lo providt • IiLIl !CpO" 01\ LIIf rquiuory ond 

Id ... islnli>e lII:tions .Ylilablt to t!J:: Dq.unm: by Sep!cmbct- I, 200S." ~ haJ 

_ed~ionsbills. 

n:1I;oded simi .. dmtioa 10 Hl'D in ~CI1II ~ ~ rcpon$ ~ 

Sinee AUCUIl 2003 ond ill _i.-t )'tIn. NAHRO haJ ~ed IhIL t!J:: Depwnera 1I'Il, ~ 

1Orvt"lrll wilh m. Itgulaory rd:rms in ordrt to Ilr::h.it,t grtat .. propm IIltamlinirlg and 

t/f!Cien(:~. grealer bea[ fluibi liY.loo roil wriniS within w HCV JIfOiIlIIl. [n w majority of 

CIK1. (hex Itiulalocy Ind JdminiSlflli,~ Itforms do 1101 rtqILR Illy rxw Icgisbtion or 

Idd.iooal IIpIIfOprialions. NAHRO'I rmllI1I!Xrmlions 1l1~ to -.ric w riP: bolana: 

bel_n reducing adminisLraLi>e \wOe", rftII~ilc from SecI""I1<r\lIII..baIed .w:htr 5III~es. 

rquJllions ard admaristnli."t,.i-antru alona "iIh iIIcrtasq: w lYIillbi[i:y ~ uislq 

f_il[ rt5CMttS 10 !'HAs iIr JIIIf1IOKS oIlUp1tflilc lin dirully ~ OIWOq 

Idministnli."t m 

The Il!atMI oIoxu=u lilt 0\1" ~ies .. ·thO! nch orm. tin.. ..-jot c:rttpits of ~b!ory 

lind Idministrll;'. reco....". .. ionJ. AlLIItilmonl.! n:1Idos ...comnrndaIions for redutiLl 

PIIM IIdminiwali>~ MO:Il$. "'uac:ttnx~ 2 okals ... ih .-irI& oppontmi:irs iIr OlJ&OinC 

Idministnli~ rtf ItI'fIllXS witin nistirt Itsoortn. AILIItILrnrn! 1 obis wi h bola""inl 

.,~rts 10 HUD's !nforrnl1ion T~d\l1l,)1ogy !)lltms ... h oacorc IdmiListtI!i> .. f .. 

fulll .... aJ .. ell az i"'P'V"r. HlID'I ItJIIIILOI)' nm...ork...J IIUO', HCV AdmiLiIual~ t 

Foe Swdy. TheS< m:lIfIIIIItrda1io11. l irfIemtnted. "ill p1l"idr ""s "iIh sWIIanlill Itlirf 

..J _kI bt iqIItmmLed iL. sho:L period ofmx. 
133 


In addili::ln to 011' regulatory I<Id Idminislra!i\"e rtCO!1IIIlendationl, we hne en(losed IK'Wly 

dnebptd rewmrnrnckd kjisllln"t language (An.:hmffl 4l In'm, the HUD S«rewy the 

~ 10 "Voe dree specifIC Section I _-bIsed >'OIICher IW'*")' ~Rmern We ~ 

pnlyidirc this ~ to )011 in the hope [hat tbe ~ITIC''' .. ill scek. quiek tnaet~ 

through tbe identifICation oh viable iegislalil'e l'Chicle. 

Up;Hl requfSI, "C o;an pnl.idt eopies of III of NAHRO·s prt".'1:IIrIIy recorrmrnded rdol'lI"5 10 

5«I1Jn I ."OUther program$. 'rocbled reconvnendationl related 10 the Idministration of ~ion 

I trnanl~ VOlll:!lcr pnlgn.~; [be use ofHou!ing Aui$l.ln« Payment! and Net Reslrirlo;l 

tlAP Assets: the S«ti)n E;p MJr.&t'IIItnt Assmmtnt Program (SEMAP): porubili:)'; and 

impro.mau MI HUO·s lnilnralion Tectn:olocr S)1Ie!ItS, 'rockodinc PIC and the VIlIICher 

M~ S)'tm (VMS~ All of 011' Iddiional regulatory and Idministrati."t refi:llms in 

these 1Iel$ 11m filed on MI~ 1, 2011 lI,ith HUO·s Regulations Division .. ·ith tbe OffICe of 

Gmml Counstl in rt5pOllSt 10 Eucll'ive Ordet IlID- Redlll:irc Regulllory Burden; 

~Rniew . 

.... 2'UI 
134 


J'~i.!I'i NAHRO 

AUI~hmtQt I . Rll<lucing 

---PItAJ' Admi~isI"'ti.t BDnltld 

I) SIUp"~d SEMAP RlIlings for PUrpo5tS or SaDtli(la$ Imd Provide Ad"isory Swm Oaly 

(24CFR 985) 

NAHRO u!'Ider$uMs the imponilOO: ~f a viable Section Eight Managemem AI$t'SSJnerll 

Program (SEMAP). We Wert pleaStd LO panicip,lle in tile: Oq.Iaruntnt's inilill;''t on SEMAP 

rtform in March 2010 along "'ilh PHAs and PHA industry group$, and we submil1N e.<lens;". 

r=mmendalions 10 HUD plH regarding s£.~w ",fum on ().;lOher 30, UllO. PHAs 

experic:r;,;o:d atlcmplS by some during tile I1s1 admini!ll'11ion 10 "nfa~ly charal:ttriu PHAs' 

progwn performarl<X' and .. ~ graI:fu11O be: able 10 cne IlVD's snw ratings for lM~ 

respectil't agencies in orde:r 10 refute lime SlaJ.emo:nI$. HUD's SE~W ralings sen-c an 

imporurn ~ fo!' HUD, Congms. the communities in ",hic:h PHAs operate and American 

Wlpa),CfS .. he pay mnhe program. 

""'Me It$$ than llree portt" ofPHAI thai. administer !he HCV If1JSI3lI1I1t rated 11)' HUD's SEMAP 

IS 'lroubled, - 25 ptIW1 of rnporodats 10 NAHRO"s r=rt 511\'t'}' ildicated thai, if tb: pmeIlly 

amicip.1ted ellS 10 !he adminimti-t ftt 3rt ir4>krm.:c:J, ~ .. wid fall irlo "troubled" SE~W' 

SUlus. Sixty-l\\Q percm of ~ presmly rated as "higll-~ under SEMAP ItaIaI 

thai. !beywould faD from "big!! pcrfunm" 10 "slan.iard ptrbmer" S£MAP !latus. 

This !:lid, !he SE.\.IAP systtm aswmes thaI PHAs \lill ha\'( adequate INlUI'CtS to 00fTlI1y "'ih 

program I'tQ'JrnnetlS. Given lhe j:tOspct1i'l" dwth of linandal rnourt'a pro,it\ed to PHAs to 

aimmister Sediln 8.QUCber programs ill FY 2011 urder P.L. 111·38) it is app1lflriaIe!hat the 

Deparllml romider 1l.I.Iprnl~ SEMAP mirrgs M- pIIIJmn of sanc\iom., ~il such lime: as ongoing 

adminisuali,'~ fees are sub$tartilll~ rtSIOrtd. UNiI thallime. HUD ~~ pro"~ PHAs ... ih 

SEMAP :;corn Ihat art ao:I>'isory only. [Any PHA ... iII 'troubled'" SEMAP f3tilgs "ior 10 the: 

~m:rl ¢f P.L. 11 \·383 sOOu~ ~main "'bjo:! to is Corno;ti ... At:tion Plan (CAP) ... iII HUD. 

ho"tlu, iptCial oonsidmltion shou~ be given lhese PHAs ,,'ih mpca 1O!Iftl~ I!.:: lime Iiarncs 

IOrlhei"CAPI.] 

w. recognize Ihat i is likely Ihat ad>'iwIy snw oc«tS "in flol] ~ to dramati;ally reduced 

cmgoilg adm;'is!mr.e fee\.. Ho\\l"vtr, " .. belim il is Onp:lrtalt thal Co.wtss uo:lerruIrd thal proper 

Iim:li-@of PHA1 ~r.g admin~'l" fees are neceswy to M SUC«$Sful $edioll 8 vouctlef 

programs ;, co"..,lia/IC-e "ih program rules. 

We lpp!"eCill. I!.:: Deparunen(s iniliali.'e on SEMAP r.form in March 2010. as .... 11 as )UUf 

in,'o!>'cmenl of PHAs and PHA indU>1!)' group!' ideas on lh:5e impo/Wll prognm 2/'e3S, 
135 


Ac~~leraling the ru"'making proctll in I~is amo and .dop1i1g OIIt SEMAP ftOOntIIl<nda!ions 

abo'-e in the meantime '!look! he III(lSi tpprtcialed byNAHRO aod OUI PHA membn's. 

2) Susptnd Or modi~' ttrUia program req~irtlllf'llb ptndillg I'I'SIOllltioa ohdftlu ~ fuDdiDg 

klradminil!rlti\'t fees 

NAHRO also.ll.lg&tlS thai UI1!il ~ fiIDd~ for adminiItlali\t fru is It:SIOred.Iht Depanme!l! 

sb:lIlk! modify progran ItqIIItmeru 10 rtflttt the capKlyof agencies urodef ttduced fuOOiIl\lt-.-e1s. 

Signifnnt Idmin~i\t rtl~fis nmkd in Ilindy fashion. 

We belim the illiowing rtq"~ srouk! be modif...:l Of susp:rd«i: 

Family income ItriflC1l1ion - SU!JICOO the Itrifx.alion requremrnl and rtly on family 

(tIIifotalions Of, emaI~-eIy, modify this rtqumnm to sKnplify I (Stt sp«iflC ~ 

doescrilxd bebw); 

ee.~ family iI1o:.>mt- bs frtque!l!ly than 2InII~ 

CiJndu.:t housing qualiy insptcIiom less frtquen.1y IhIIl arnn!Iy; 

E~mN!e q..a11)'C()III(II i'I!JICdions; 

Reb., deadlil>es ilr corrtdion of housilg quaIi~ dtflCim::its- 0Ih:r than txiga'l lIelI~h and 

safety I'io laiions; 

ElimawesancticmsbrflliMtto usc. leaS! OO%of\~orfunding; 

SuspmI requmr.:1lS to e:<p1lld hous,"€ ~hon <Uside 31taS of PO'tfl), or mmrlY 

coo;ertnIion: and 

SuspeOO requmoots 10 CIYOII familts in ihe family $df.sufflCienry (FSS) pnlp1m aM to 

~Ip FSS ]imilies acltieve i1c= in tIll'lo)TTal n.ome. 

I'roptf selection of applnm from the housi'1 ,lion .oocller IIli1i'11s inc:Ufug inrom:: 

wgttilg; 

SoIn:I de!mnina1ion of rtUlIIIIbk!trl only .,iill rent rea§()!J3bleress dtIennilations (but 

IllI K>r1Flll31 rent ~ deImninaiiJns); 

EsIabIishnIC!t of Plymert!Urr:lan!s IIUin the requftd ~ of the HUD fU rr.arXe1 rent: 

Correct calculaloo of the lmarl !Iwt of the rent ;nj the housing assistance paymc:nl, 

HoIIntf, 111m iI com:s 10 .gptga!,"€ "impropa' pa)merts'" from PHAs' I100me and rent 

calculation!, lit helielt thai PHAs ,hluk! be fflmpllOr frnancial pena~ies ~o;ociued IIU 

""" M.i:terwICe '"""" of • .;unaI.1Cho:!u1e ofallow-ances for IC!Wt uiliy= 

Ensure unu co""",1y lIilh the housilg quality Slandards befort famil~s mer into leases and 

PHAs enIer no Iv:lI6ing assilamlCe roTW.U K>r the bso-up ofiniiaJ unu to the program as 

,,-eU 1.1 interim or ~birlllspttlions of cmergeoc)' b:a~h and safety ~iJ!ations {bJI 

IIlI ~3MIIaIHQS ~ions);and 

poTUbilily. 
136 


J) Diaillilllrd eo..plillft.ir~ IICV P1vIn. .. R"I "irtenls n.r 10 hadiac limssir.atts 

• Ou~ ill HUD', Rtspoaw to RrallllBlndahGu 1l'0III tilt ~ or tilt I~ 

GHfI'lI (24 eFR \'01. 50 s.btitlt B, CUpt.,. XII) 

As )l1li know. H\JO's Offlet of tile IIl5p«LOf Gtneral CO,.jut15 aWu insptttlms and 

(ll!\IIlions of PilAt' iidministillion ofHUD programs includina S«tion 8 lelW'll·ba$ed ,1lUCher 

progrllll$. In lig/ll of the dnstie doIl1l"'1I'(I pro-nIions of ongon. ildmmistl1li .. e 1«5 ill Section 

I 1tmIl..bwd voocber programs ond PHAf 5!lb5tanIial 1IOII-((l""liante that may ensue. 

NAHRO rmlllIIII:OOs tIat IlUD issue JIIidanct 10 the DcpInmnt Field II1II Res~ Officn 

rtpnIa., future DIG IUdis. \\"0 rt$ptCt 11) peri)ds ",11m OIIIO~ u"ist,.i .. e ~ ~ 

l'Itions In: bep 90 pcfttII. "'t ~ tt.t HUD irIsmItt is ReJioDallnli field Offlm 

tbIl. iIbJt!t HUD OIG rad"'gs of b.>d or aw:, III) fWllDeill pendin lSSOt~ed lIitb 

proptMllli: no~liantt not M upheld b)' the Dq:ranmtll. PItAs 1111'( tltry fttItion 10 

fully tIlmply h HUO m'[u;.c1lll:lU InsttJd of imposing [lIIlnI:ial penII_in th.t would further 

nodi: lhe lbit~y of II'!IA 10 fIllly eomply. HUD should .'or'< dosel)' w~h PHAs 10 \krelop II1II 

impkmtll ~t(orrt(li\'e l(tiQl'I1lO mnedytbe r<ndingsilM be in OOIIfliante lI'ith HUD 

requirtlMlU. 

41 Rdo,.iI, HUD', ~ A«ruI AffiMI~tiaJ Metltod ill \~IS 

III IrnnS oflOlll HAl' nptrJIitlftS, the dil'rmntts betl\ftll 1fIe IMbod HUD antntly m'[um 

of I'IIAs in the~ lIIlIOl): VMS 511tmi$~ 11111Ix rtCOOUrII:ndltion "'~ ineomt t!w is Mt 

COIItIted until cash (or a dlCt~) is Ktlllily m:'ei,'ed and Ho\I$iIg M~ hym.nI (HAl') 

OjICn5tS an: not rounl.d unlil the), an: KIIIIII)' PIIid. art immalCrial. 105 Mh. NAHRO's 

recollVl'lCroded IIOCOWltlng mtLhod (1I1ac~) lloold be romplianl ~ Generally AC«pled 

AceoLmIirL& I'!inciplts (GAAP) !\lin. 

S} Supnd Reqlrimllftt lor PHAs 10 Vtrify ~' "EIdtttItd _~ 0!Mr TUm 

nro.p~tx.s 

Siqllify !'HAs' mt mulaioots by lUSpehl~ 1Ix ~ ID 'uify "m:bkod iIrorn:" itnnI.. 

lifdtt this ~ion. hou!dxlk!s ",wid still be rcqmd 10 ~ "mbkod nome" tans but 

~!be SUspmloo perDd, PHAs slDuid be Ilbll~ 10 ~ ~1d'1 5tlJ.mtifltalm on 

"ncUXd incomc:" klTli soch as: 

any nputed ftlLrn OIL ~5; 

food~: 

Wle; 

.y amowtIS tIat _Id be e!ia:ibk b' =brWrI.nIer sectiol!I6U(aX7) ofllx SOOaI 

SmriIy Acl (42 U.s.c. Ill1ll(l)(1)}; 

defnml d~bilil)"btno:fll5lTom lbe DeputmrntufVtlennsArr,inth.t ~ rtOOI'e\l in I 

Iu.mp 111m all'Ollni or in pro$p«1i\oe II'IOmhly lmoum; 

etrrcd inrolllC of any dtpm:!ent earned doling any pniod thal IIICh dependent is 

IIImdint! school Of .'oeItional lrain~ on I full-lime basis or Illy gn.m·m.,il! ur 

scMlinhip ~ rtilled 10 IlICIt llleodance IMd b'!be tIlIl ofwitiol'l or books; 
137 


III) _Ill iI or lion!. 01' lIlY benrfu &11m. any CO>'CfddledutMioD 'lI'q;s ItCOUIlI 

UDiIer !«tiKI no of Ibt lruma) RmlUt Cod< of 1916 01' tay quIIijflCd lIIi1iK1 progr1III 

unXr!('[lion 529 ofsudlCodr; and any III'.C\InI rtqUftd by Ftdmliaw III be=kIded 

ItQm considmlr.BI$ il«l~. 

We rtColl1!llelld HUD permit PHAILO elimin.lt< Ihis req u~mtRlU l/lej-d iso;mion. 

6) Rt>ise Hitrartll)· of larotnt VftiflCll lm Mrthocb by AlIoIoi., UK of IIOUKhldl' fly 

SllhI u i. lilt Firs! St! 01 Ral l.:ilP (24 erR 960.l59(c) aid 24 CfR 98l.516(.}) 

Ewm wilh \br; aistq Ert~ ll1t01!1r VttiflCllioa (ElY) S)1Iem. PIiAs 5Iill-' 10 re1y on 

lI*.l.iona~ _I IImJ pany vtI'iIitMioII of I!coIrE lppI1»irMtly 40 pemrJ of Ibc: time. 

'II"hich is tint COfI\lI!I\iftg. bun:Im!ome .1Id administr3li,.ely expenstlf b- PKAs. In furthmnct 

of n:1II simplifKUion 'lie rmlIIImi:lId IIUD revist is hirnln:hy or income vtrifKat'on m::thods. 

b)· gioiing PHAs t/le opportunil~ 10 use household provided pay stubs 10 \"erify income from 

t"TI"flo)·m::nt 1$ I fn! rankC<! iem in lilt hierarchy. Thi! 'IIo~ tJelp lO ~ilm ine the: 

O"trifntDnofiloomt. 

7) I. plt .... ' Siapifxd I'nIms for Idtllif,-i., HOII§titoid 1_ PrieN" 10 Rn.t 

CalnllltiHs, 10 RNI" IlIIproptr hyllfllil (24 crR § S. ' l, ud tOI) 

IIid iI not bmI wihdn.'IIl1, fWD·, J-, 27, 2009 filiI w. ItflllfllXnI- rvlr defmilion of 

anrwl i'ocom:: 'II"011id ha--e eMbled PHAs II their distn:lion lO ~Iy pa$I ...-111:11 income 

Ittci.C<!O!" eamtd wilhin the 1as11 2 monwofthe detmninal.iondate, IS HUD may pmcribe in 

applitabk Idministntil'e ~iol\$ ... - ~bly. after tiling o/fK •. IiVD withdltw one of 

the most ~1IIItip«ts of the qinll"'Tenl n:fllltmenl"!\I1e after ill2O-day rmraurimt on 

pcMinareplotions. The J'I"POSt ofHUD', "'" .. flf\ftJltl"ll ",It ..... 10 sttrngthnl inoomr mI 

mt ncp1j\ IS 'lid IS $i\'flil)-ea the iDcornt pnxm II rm:In iI more KQII1I •• thereby 

rt4.:q 0\tf'pa)1IItlIS. Rf>tnq t.:k 10 the aQq defdliioQ of anrmI ix:om:: did 11)1 

~i!h _ oflbc mait qilll propo$ed pwposcs oflbc "mI rtfllltmCll" M:." 

On Ikcmta 29, 2009 HUD '11101t, '1lUD is a .. -w of the need 10 IdcR$s Ibc issue ofamgj O;om:: 

and irkrm 10 Plrtss Ihfi iwe.- II is worth OOIng IhM 'IIk n lile [)qJammJt !I.b:n«ted ls FY 2012 

twlCl ~ OJ!Iaining • rMnber of·"rtIC sinpti;ily" provi!r.1"!Ii fi-om SEVRA, al:s:n\ .. en: 

provisM5 rtlllqlO.ved iIlusthckl O;om:: am mn ~iorlS b) ~1'HAs1O II!IC 

~~ IlUIII pI5l Rune from It.: jttI--j)us 1'II~!-'"&-lMIIhs Of amft inootnt IIl1icCpatnj b 

Ik iI[bo,·q I'iId."C-IIllIIhi. Thii 'pedrO!: itm iom Ik «WillI ""mt ~~ nenn ",Ie is 

~ It. HUD C1II do """·1IwuP tqUiIIi."ct "ih.u: hlo", 10 itrocW qisIIIi\~ Iquagc Of ..... III tIM 1opID~ IquIgt cnwd no ..... 

Under Ik Jarury27, 2009 f ... 1 "'k ,,!WI '11l1l11er ~ and rtritde<.l by HUD. PHAs woutl 

hll·f bmI abk ID t5l3bIish ~l'cics!hal '11m beneficial and fair 10 k1 ...... mxn. ~kIs. IIJ:Irt 

ldmini5lnt i'·~1y manag~bIt 10 PHA$. and rtSpJIIIible 10 1a."IpI)m .. ho furJ.I th: awli:ablt 

FfO&IIITII. This is fSlicularly I!\II: iI)~ "htn less than 100 perterII prtJ-It:i)n is prol·ijcl in 

liousq A$$isln:e Pa)"mt·1IS Ind ldmi!isniI~ fees 1:1 has l:«n IlK: o;a,e and l1li). comiraIe iI th: 
138 


NUft, PHAs sbluld IWlIIII't IOltt\t rc-.~ ~ nor III QlIIM 10 11M ui$I~ lKlusc:h:IiiI 

pa)"il& hPr mI Iudm! !IIIn !hey ~ilr ~ IhIeI- tht JIcuwy 27, 2009 rmJ rule's 

IItfIllU.l!l or_I inromc. 

~ 

PlIA$ '11m pmnC\<d 10 appIy.:ross tht bocd ~ ro $!lCiIIl seo:\rly 'It'ilW tim! part)' 

bad iI tht 1970's. We IIrl: 001 mil .. 'ltflmor .. lIy this clwctd fur d:lerl!o' and 

disabled housdmtls Ii<.q 011 r..d iI:ornt$. !be only 1I'nIlI1d;.sa.- 10 ~ is I)pically !be 

cmt of w" IdjIsbmI &om tht SoaII ~ AdminismIion, .. iIitb ~ br easily abllud II)' 

Ibr PHIl . 'i/oa dnilisIaq: W Mn JtCJedifUiln jIfltIS. Rlr III)' housdmt!s.hctt 90 

perte1I ornmoftIU housebol:l in:omI: ft from lliud sotm(s). HUD.,..U pnni PHAs 10 

apply tht applicable amIZI ~ ~ 10 thti" fl'<ed brnerl (c", SS« SSJ) or ~ ,dlCd 

HUD's ElV system 10 dnmnR lIri' ImIIl ilcomt br rtI'I ClIruIMi;ln. In tht)nt'$ .... hich 

PHA$' " ill not be rtqIimllO oonduc1l romptehcn$;"~ lI1I'lIIl housch:ll:l JtCJedifl("lIIiJn, b:>useb.11d 

irIcomc 'ItOU1d be: JtCJediflCd I!rough IItlIP of iIconr docunrTIs pro>iIed by W IIIIIschold and 

Q'\l$$o~ .. 'IlI I{lJO's Emrpist-I_ \,crif"!(IID, (EIVJ I)51C1n. The 1IIIIsd>J1d...,.,,1d be: 

~mllO ~ that tht inromt rtpomd is II\Ie IIld COOfktc iIr I Vven P"fild ohint. TakilJ 

~ meum _Id men lhr SIWOr)" ItqUftmat b arnal ft',n.l of hou!r!mld iJoocnn and 

tdu ptIA$' admiti!lnlM Iuden!.. 

9) ~nified lI-u.otI AMttsr.401l. tMl.~lJId!4 CfRf~ 6) 

We namrnm;l ~Ib'lting "t.t is 60nr ~ !be (.ow.lneorn: HouIinB Tall Cmll (LIIITC) 

IJOS!Im by IlkI'lting OOo.rsehJkh 10 il'1f-«rtify under the pans and pmalies of ~j.I'Y !be .. lSSCU of 

1m Ihln SS,OOJ. UnJer this S)'SICm, if 11Ii;Ma1lo1d mlilies II5Il:ti of 1m than SS,OOl than I PHA 

'"'IlUIII1II ... OIIisDed B "", ... 1NtI. Grnmtly only I few"*"1) ItnllU hi... IIIJle .&nnW< nr 

I:SSCIS. Theamn~ ilr PHAsIO>riY hou!r!m!ds' iii rno«lIlI~ ~acavI 

~ that a:w:&IiI moon. S\II!II is tinr~ n! r..nanl 

IOjAIlIrwu.r: PHM 10 Use '- aM ~ eon.posifiaI Dtltn:aiaatiolls by O!kr 

AppliClblr Gol'mlmmlJl r.t~le:s 

AI tb:: dilc:mion of tb:: PHA 1m 'ltlh I safe harbor proviIOJn from !IUD, !be ~ mil 

enable boIIstllold iIoonr mJ OOfllIOSitm JtCJedifl("lIm ~ by oclJrr frdmllUte. or loCI.! 

"I'\llmllllMl Mii=i (b ~ IJH"I'\AssisIcd b.lusemkll. TAo" agma) 10 !WId in pbcc b 

PH,\$' ~y 6etennNli:I!II of !!ppIiCIrt housdoIds IIld lmfIificaiom of pIr'Ii>,*" 

Imu!dIlkls. This ~ ctIUId br J.:mmI ' PHAs It IIri' d~ 1$ drfJ,e.;l in m 

MrDism n! ~ PIIn. 10 ..,.. 1$ !be daI. of dttmrn.-.. is "'iIhin 12 II"IRhs of 

IppbI hoII!dI!t!s' .Ji&ibility ~io!I or pri:~ hoII!dI!lds' lmIh or IrIIIIl 

ro;cnifdixl drm~" dIu-, 
139 


II) lillO', Ealffplist lnrom~ \'tri/iQtion (FlY) S)1tnn 

HUO'I Erl~ 1!IOOm:: VerifOljOlJ (EIV) I)Slem is a good toro:tpI, HoII't\'tr, BUD's recenI 

iIaeased roquirtrnents ofPHAs oluri1 I line of dramIIicaUy!tduced ongoq ~ministrativt kn 

plam addili:mal ewromi<: =irlo on PHAs. Just as PHAs' dismlilrs)' aulhoriy 10 M 

milal bockgroln:l clleds .nilg cligibili y delmnina1~ (octpl ~ se;(-<lff'lI!n m.l meth 

~inc sale aM distriloAioo which art mandalQry). I~ ElY lin:tixls described below art 

ilTflOll3lll to ~'irtI !he Utegn:)' of the propn. DranlIIi: rtdoc!imI il PItAs' ongoir; 

a:!miaistralivt fees make iI l'uunciall}' infeasible 10 perfunn many of!he adminimlivt functions tim 

IIIf- inpoNIJ!o ta);j:Il)"m, PIiA$. an;! the OOIl'I1lWlities Ihe)' Ito't, AdrniIlistra!i'e fuOClioM which 

\\'a't iIrnlerly dilmli:mary u11lier HUD'$ ElY guiiMtc, art now mandawIy, anlas I resuk roqui't 

PHAs!O ameoo the'r Admilliwatr.t Pbns 10 "tude: 

~ Terwt Se3rth. For adIli membm il a housc:mlj to dMmine if there are rmrues 

011'0:<1 or an aduk m::mber II'IS n I(I!>OOlll'liance \\"ilh pnl!!1M1 rub. If there is , mwoold 

dele (l\I~ to illy PHA, Ihan al'HA IlIlSI mlil» Iwscmld al tbeir bsl krown~. PHAs 

must docume!l in !he file tim tIJc)' !WIthis!t3Jtn m.l ilt tile rtSIIks; 

Deaased T.rwt Rep'"t - PHAs IlIlSI run lhii rtpOII on I morlhI}' basis. PItAs mu!l run t!lis 

rtpOII lYon for eac/l HAP check rID\; ooce!)em Mil'; IW' cW ~ aM IIIKIlher 

lime befo~ ~tearng HAP p.1),m::IlS; 

lder.lif"al ion VerifICation Repon - PHAs 1W.LIt!lll this ft!IOn on I rroatdy basis, IrPHA 

1m (OITeC! ,'tIifarion iIformaloo for !.J~ld membm (i.e, BiIh ccniflC1lle ~ dale of 

biIh. Soci1I Searl)' Card for Social So;.;rly Number, last IlIITIt an.:! fn narrJ:) \u the 

Social Sttu-iy Admin~ 1m ~ rtCOrdi, rlm PHAs IlIlSI enter inoorrcct 

info.rmIIlion ru. tho $)'3I<m.., thallhc r=rd ...t>rnU.ion o:loc$ not £Oil In these m.r.c... tho 

Inlscblld has 10 go to lh: Social SKuriy Admllistration then ~vilt !her corn:ae.:l 

irWrma!ion to tb: PHA 1I'lOCh las 10 send 1 10 HUD HeadquarttrS \IlIich in turn 1m to 

proviJe i 10 the US. Socill So;.;riyOffn H~ers n Bakim:)re; 

lmmigmion RtpOn -!'HAs !RI!lM this rtpOn on I rronIhly basis. PH~ must pro"ide 1{-

I1IIl'IWs an;! "A_ , to' I.,nnber$ to parlO:Ili3' ixMrsd'o:lld$ lID! tlaimillg US (ii;(enship. In 

these ins=, PHAs tn,-e gtt doc~ &om tbe Deparurrllt of Hom:Iarr.l S=rIYor 

t~ Social Seclriy Administration; 

Mul~S~bs'l)' Rtport - PHAs Il1lSl run thi! rtpOII <XI 11'IIOIthly basis. PHA has 10 rronior 

lind updalt quarterly I 1lwsc!.Jlfs oo"l'Mili:m ofllooscttJkl rmtlbm tim D:) hrIgcr reide 

n • \llliI:. If appli:3ble, !he PItA nw tcnnMt dupliae :mistanox or requit- family 10 

immediate temUnat( assiswn in other propn. PHAs RlISl mairtain ~ of!he 

result of duplioo ~ in each h:lozseOOld file; 
140 


~ 

~ T aart ReporI- PHA$ II'UIl ~ Jo:osD:,Id ,,'ol'CSllb of K8'dI and !itC\ft 

ofm IIW)\'C 011 of misla:! do.'CDiIf: IIli. If~, lIE PHA I11III 

COIba llEaber PIWIMr.:IkwllofllE ~kls' amnI uus:; 

Irmme Repo:t - PHA$1'IIlSI ~ Il>it5eIKlId iltbmm»n ""ih lIE 1OOrmat»n [W~ided 

iltEIV;lIId 

DebIs QI.~ Rcpon- PHAs m4 t'a I.tklg of dd:ts <IW!Id by ~ JI, 2<111 trd 

..:ay hov5dIcld. tin III kruwn IdonsL 

In prW:t BY ~ ~ ~ Ita akt the ri!~ ~i3n p-octSI ~ 

dalkrwilg ix PH.o\s. EJV -'J br rrat i'ElplillLO I'HA$ if the .wm.ion g;miDf in 

ElY "'m rrat tII'TeI1lt\:l rrat 1IttUIllr, In is ~ ron:!i:ion. Erv aauallr males 

rratWOlkix PIlM lucowbmfl \1Ilue isqueslllnable. L'$;td brb ...... I'HA$· ~igIIs 

IhliII.Ih< exilIiIlg ElY I)!!em: 

Th:: irl:onE vcrifDlion [ftKI'ICd by ElY is. least tktt ~ I:dIh:I ttE ctmIII dale. 

\\'htr\1 PHI< rur.'ft11 P'O&J:'IfI\ J*1.q,m.., di!tus!es ElY ~ion ","iIIIMm 

!'HAs fill II1II LlIIIIY t1iclI$ dispIe lh: aroncy of lIE ElY ~ imr.le ~ 

1IIdi:ilfv,1 \IIlI:'t'CSSIII' 1udm!ooIc ~ Jep5 ix !'HAs an;! [WPII pmpms. lui 

EIV syIICm dill ",m _ amnia rrat atanlC -.lI sueanin: PHA ~ ix 

mifyi!g iIoome, rtGn the tIIfUI OOfIlIhiy ill ttE ctpiliy proct5Ia i1m:zst PHA 

_yrllC, 

It i/; ~lIft ~IO fill ~ies purc/'Ilsed byaber ~ or~!hI: 

~~ uo;Ier JDXhcr ~ '*"lr {DBA~ M I ~_ in many iIurI;:n ttE [Wpm 

piIliclpn Ii II'IIhIc Il~_d'rfllln:'af lhl: ~ Ilt<d in ElY iotl",. "',.,..,)U. 

Th:: !'HAs propn ","i;~ docs not ~ lIE !lime of lh: ~ lisud in EIV 

md~"~~1I)1I1ld.o.!iionJl~iIt~ ~ 

ElY docs not "Wi: ~ bm:flfftOmt iltbmwion (~, TAt-f, food ~ Child 

SI.f!POII). PHAs 1ft rtqUi'td 10 lerify lI* r.:.:-~ 0ltET II'C3I'6. 

EIV ~ .IOu!I1II,lUnl of dierl P;o~ by quarter, To Iddrns EIV Mm: d~y 

rquts a or 10 ,'lfidac ElV'I _y, the f"OPIl r-ni:ip!a ",0\IId nmilO provlIe pay 

SIlU ix , fi.II~, ~1.1f; rqnmr;gni:~do notnuilthe .. ~ _ixtll5 blfh of~ As.I<$IIlPHAsneedlOSLbM:I~,~bmlOthe.)'lf, TODoim 

~b~ refille or iqct 10 IU\m Ibr ~1eKd ... 'mrui:la iwmI. Too iajlmty 

PU", fnI IhII: .. 11m ~ do I'CIInI lh: "'¥' mifQli.:Jn b'IPS the ixms 1ft 

~ D::omcIIy or lIE brm 5 ~ktt brcau!c the .)'(1' till omileQ xm: 

(l'ii:aJ ~ion ~ Il wrify Elv; ~ 1:I11"mge IUIf!er olb:us worIi:td per ",t«. 

It brromc:s ' "CIY ~ha le"u.: ",-tEn 1M propl1 ~i:~ doa not ~ the EIV 

rqxwd ntrne ofw 0JIIlIIII)' tilt)' -.ortb.1 for ard mil'!md! I "'1g'C verifallon iJm! to III: 
141 


~ aI tht ~ fails 10 IC:!pDlMlIO PHA ~iY$. TlIiI is. o:onmlII ~ 

rond.ilad.s WM'lObr~ 

EIV ~stem is ...., .... (1III1'liIabk h PHA~) peri;ldmly ",ftd\ IdImtly ~ PHIl 

proo.V;Ir.'iy, For e:o:amp't.!'HAs rtttr.td I 00!i:t on May 1. 201Ililld. "PIH.RHII1'.TA 

Messai'C Ii 2011·28" wh;';h!lllcS, 1'1caic be .m'ised lhaIlhm: is amnly l!lm(f issue: 

-MI;';h ",ill jXt\'tIIlBIS Qflhe PubI;'; lnd h.:lian HoW!g (Plln ElY syst<rn iom ~ 

!hi: PIH E/V s~tnd'ot iWnraIiJn .. 'i!liI!hI: S)'IInn. We It'IjWl tlIIlIgeI'S ml KttSS 

EIV.ni lhis issue: isl$llYed.· 

URc ElY ill' nain> cbqn _ Iilk: or no p:>etUl IWt to lhe PHA. h hc:~ 1(1 

idcnI:il)' w kw ~ pMiriparu lflii fail 10 ~ or ICXIntriy rtport inooIne 

!.:lima; ~ lhe ElY data iI ill kaslll= ITIOIdts ok!. by oklinllixl tIw: prugrmI 

~;';i;IInl iI pcrliJmring III min darrge JtPOIIi¥ I ~ iI D:omr 1M; omrnd .. ,m 

the Illl ten d:I)'$. 

R~tht resc:ixledprolisi:Jnoftht "1tIt I':fn:mcnI"I\Ik:(~ iI~iJn IJlII'ber 

silI.t.:M:) ~ a 1b::r d$ftli)Q, I'HM coukI JAlI)' ~Iis' pd IttUII D:omr rtetMd or 

arml .. 1hin tht lIsI 12 IlUlbs oftht dMmilaim d:ilt' ~ erubIc: !'HAs 10 Il~ EIV 10 

~ Rom: l1li .en: rug,;y, IS ",d 11$ linpiI)~ lhe D:omr proce$$ 10 mIIcr i nm: 

amnle, 1Meb)'rW:q ClIer-p)1llC!II$. 

PHAs des" 10 pllWU: 13k. ~ afbdable ~iIIg 10 eligible ~'d$. PHAs aitJ oksK to 

a.:tIDlely cIeItnnIr income UIIi elisibiliy of progmn par!ieipuu l1li10 <tW.:e ~\01IIe nllirnely 

raul 1'o:ll.iIq; ~ pI)'ImtS. NO .... !IlJft linn ever before, PlIAs ne«I IIUD', hc:~ and 

roopmIm 10 fnj rmorBbIe IlIU:OOS to ~i¥ tht effil:im:y and df«1htmS oflhe digllilil)' 

ducnui,.ioft ~ h iI our hop< Ilooc Iho obo", inbmoIioft ,,'ill pI'C!I'idt _il .. ~ 10 

HOD rtp\lq lhe ElY iriiar.e II!.:I iI',*, tilJl) 10 C(lftiu I diaklpe ~ NAHRO and PHAs 10 

r.aJ ItISOIlIbIt IlIUim 1fIII.\~ 1hc: HCV pNpI\ 

U) RtJot--ia, Utility Allo ...... ns (2 ~ efR 982.51 7) 

The COli of ~h uti'~y and bou~ $mice ClltgO!)' muS! be swcd separllely. For each oflhe!t 

Cltegories. the lI1il~y .1I0"-'l1I:t sehedule nJISI like Uto romidmllion un. silt (by number of 

bedroom5~ and unil r,pe$ (e.g, iplllmell, 1O .. 'house. lO",n boux. sir1;ie-family ~ Ind 

matIIfactuml ~ thai ft I)"picalil !be _'y. 

NAHRO rrcormnds HUD 10 altIw in~ parties 10 be abIt 10 a;xrmeaI 011 !hi: kIIiliy 

torI',oIIt!I offMR$ ~Iely front mil in !be olmn Iml off MRs. IfdJ: n.unbcr ofmdal 

obsm-.ilns iI suifltiml in dJ: ArmUn Conmmir Sun")' and.'or A~an Housin8 Stroey 

~ IIUD should pro,i.k PHAs "'K/llhc: Uli(iydlla i SIIhm from lhe III/IUII far Mmft Rent 

(FMR) cllcuwioll5. III thaI t'ery PHA docs Illl hale 10 woknaI;t !he; o"n lIliliy "udie5 .. 'hic:h 

can be lime tQ!IlIJming and an Ioddilional (;;pense.. If the n~mber of rtntll ~ions is 

suif.clenl. PHAs should be ilble 10 use 1~lirltd lIliiiy Ilil"lfft !iClltdules II:! bNroom lilt 

0fIi)'. "'lh>In .w.ionalaIlO .... I~ by.1I building l)pe$ (it, hish rise, gII'Ikn &: 10", ftt.). Al 
142 


the ''trY Dsl. pubIisbln& Ibis lIIail, infolflllliorl tad! )Ur .. oaId ~bIO: PHAs 10 kau .... ~ 

or ro; lItijly I'IIt:S iInmtd II)' 10 pm'C!II or 111M &om. PHA's lid. rtmW. lIilly a1kJ .. 'IIUS. 

ill om IQ delem;ir,t " 'htthef or IlOl COI'Id\oI;Iing tner$\t "kldalions of lII~ly riles rod 

I'Omllmpcion ",·m nmXd, In addiiDn. PHAs should bt ,bit 10 II$t the lIIili) alkl"''lnCe of. 

houKholofs IUthorized youchef ,il:t if the bedroom IQe orlbeir ltU«l <Jni! is Jm.l~ than their 

~thoriztd ,tluchef sizt, PllAs should .lso lit alb>l-N to ~se tbe k1wtl of !her utility 

companies' "lifeline" r1te$ 01 the Slatdard rommm;ial ratt JVqts .. hm applicable. These 

!IIeI$UI't$ would lrwly sin1>lify!be ~ine p!'\"U$$ b YOUdIer hoklfn QJj prtlpmy \Y<olXf1, I(l 

belp = Ins prtlpnmat~ bwrim to knr.~ wislo.:l hcx4dll1ib Kcruin& !be holllill 

martel Itllf:r.~ 10 WIISSisItd hau!rholds. 

Aaemllil>:ty, HUD s/'Iould flHiI/Il\'fIIF nmJ UliIiy~!If I:IDo:lm silt ill lieu of tIiIiy 

aJkI"anc:et by SII!K1!n ~pe« I 1111 !liliy ,1bv.'Iru 11). bcotoom ~ Am1Iw:t ~ QJ\II:t be 

that PlIAs would be 11* to !MYt)'!her 1m! !lilly ~ W ~ion mes. O:Iamelllhtm, 

rod IIf!I"IXIle 1Imge5 by I:m'oom sile .• 110 HUD appro,oaL This "oulclligniflC:l.rtty ..duct the 

~y ani g,blblion CITM by PHAJ kor utiIi.~ allJ,,'3I'IC:e$ W make the program rmre 

ImISpIm1t 10 J:IO!II«1i\~ property \Y<oTa'S rod ,"OlII:Ia·assisto.:l ~1Js. 

IJ) AmllIO HtID Prosl'llllS *" Ptno. .... Limikd F.ap!III'toIlcieKy ~ 0nItr 

1l16i) 

HUD'J>IIImt t.nUd ~ I'roflC:imty (LEP) lIIik1m Jt:qUtt PHAJ. 0I\Ta'S ani rranagm to 

prtl'U " r'IIalm orallr1Mbtiom of"vur doo:~ in an IITlY ofl;w~ languages kif i.\Sisto.:l 

hauscIJolds ",1J, limicd Ertlish pcoflC:irnc), Conscrva!ive estilMtts put LEP hw!ch:llds .. tht 

S«ti:ln 1)I'OpIlIII approxinateiy 2&a,000 how:holds nati:I!M';.x. Docu~ Ir1nIbtiln rates 'W}'. 

bUlll)picaJ leur. -..wid ~ (Oil abooJ: $1,000 10 ttwlate no 15~1c iquIge. mI i:>r III of 

lloo .,...".., ro:I ogor1$ ~;u. "'"' IND ~ the 10UI <OS! ""lUkI be 0- S60 mil!m. 

lIIl tnndaions iID jist tt.tt ~es kif Ibe:sc progr1InI-.ld uaaI $112 millon. A. 

ttrIIIl1flllllllioa. HUD ofaD ,w propn doamtrfS lIIl.ebcist mllnIIIIIli.n would F.O'im 

pier JUndIrd"~ioI1 and JIObIbIy IIigha' ~of~ .I.rrue!I Ioooer Cd 

Be)Olll the HUD ~ ,moly 1I'IrIIIIud .00 IX*td by tbI: ~ .: 

mWllxm.ttu:! ~rtJWMVl I1Jp ?stc"1I'QIOI!I 0[1\'£,1&;' Mu.;iwJll",,1 gm'OO)QX!Iqllllkp 

NAHRO rmlII1II1tIIds HUD dc:,'tklp ar,;l make lwi bable IrMIwOOi or. lis! of ·'iUr doo"""nI$ 

dc:',eklped tImIgII. HUQ.con.."tIXd TlIk Forte. ~-iIg 0..: a pan 10 ~ accm 10 propns 

aid 

~ 

K1;'·ila b irdi,ll\laIs "'&h ~ fI1li1h profl:it!E)~ alii t:I "'. 2+1w"1Ol\-me!De kif 

~iDeS. If I ~ mjIIe51lO Corwoss iJ IIMSed b the Trnixmai;m 

1niI.;'~ 10 ply iJr HUD'1 bI iet 1ft. NAHRO rtUIIlIlImIs It. !he ~ make this 

~ AUmMiveIy. ""!1m and !IlIflII't!S mid be ~ iJr 1I'InSIItion n;pmses. This 

10001,111(, ...... ' dco:s !Ill irdodr any omIifntlon oftbl: tile: VI Civil RCfu!ott. rules. rtgUlaOOns, 

lIliiatn. «()Idm of gmml appIQbilly pn.o.r:IlO such !\.Ct.«IIIY r._;'e onIm. 
143 


J lailial t.sptcIiDtiflf PHAir .... t\! t:aib.-*r P'ro;«t-Ba.d \'oatr Pflllrllllll ~ CFR § 

9U"!~ 

UnIa' Ihr cxislit;I'!uFt-Bmd vouther (PH\') ~.i:NI [24 QR § 9S3J9(O] •• PHA that c ... ns 

or ~i"ly a)I'trOls III nt~ IhM 01<1'11' ~~ I't ~m to o;xma ",ill aoxhtr 

eligible CI1liy to pnbm inilial !Iou!;" Qualiy Slandard (llQS) nsptdions. HlID o.rl!l<S I 

ck-.~bpmenI a:)ftrQ!led by I PHA or 1/1 my tNt iJ ___ .lIy ~Ikd by I PHA ",tuc:h o ... ns 1 

de>mpnert. ... hat!he PHA. insInInerolIy or affilill.e hI't leu !han CQI: pem"II fane" or 

OI\~ of 1 ck-.ebpmenl. Tho jQaitaldiia of ailtit; rqulllicn iJ tt.. .. all CIKS. !'HAs I't 

requRd III spmI U!.iJn/ IIIHIics III IMrIa b Ihr iUl HQS ilsptam Ibm Iht)' odla-..'iK 

'MlO,Iij b..,.other PHV ck-.~ or~n" IN: ill\mlrf:-med ~ mi!u:u_ 

HUD',cxisI" rqulllm IIOC onI)' ~ .. mtm ~ b PlIAs, 1IIIIhr)':R ~ 

... lh other HUD ~m b other PIiA.o-..Ttd j:IIljcct-based ~'t~ !'HAs 0"0'011 Publi: 

IIousR1 cbebpll1l:nts aOO pcrlOOn .m on Iirr ~ning U!lu. Both PBV ck>e~ 

o-..mI by PHAs aOO Publi: HousIJi dele~ own:d by PHAs, are su~ to qually C()IIIIlI 

~ions by PH" managemm. to !II!U'e IhaIIhr i'II;>ections c:onw ... ·iII HUV rqulal~ In IIr 

!:ale of rmA POV nklpn'als, 11m I't \ISIaIy other addWnI.J 1II)C1'1 offirll.n:" sudI as \.010'-

1_ HoIzq: T 1"1 Crtdis, Mortpge 1lt\'fIU: 80rIk e!£, Tho ~i;Jn of othcr ilspcailll 

requm-s tom Ihr other ~ Ip'm ~ IIX O'edils an$ b:In1,,,o' .. i6e m:dIa 

chcd: and baIarJ;c 10 CII5I.ft HUD', 1Iou:sq;.p1Xy I1mhds I't inti 1 miinun aOO liil1iil)' 

~rtq\li-e~tolfl'(ft~UIdG. 

"k~!hl las! poil iJ IIOC dftctly relattd 10 011' reqJtSI b-1IdrninistnIM: relid'''''lMI HUD'I 

exislit; resulalor: ~iew. !be ScttiDn E" Voudxr RefOnn Act '-. provist.ln thai "'ll'Jkl alb-..' 

iupections ~ by. milic:s b- tu m:di ~ ill example. to be used II pbn of. 

PIt\ -.dutI.d HQS.,ioft. \\'. ft IIOC ~ Ihil pr<l'IiI"" fimI Sf.VRA as i iJ IIOC 

",IhiIIIUV'1 exiltilf: ~ 1U"irw. We IlICIIlln iI siJW 10 b!1It 1M HUD'sailtilc 

rqulatilns ~ III oodue ~ on !'HAs to a:DrKt0ll. ililial HQS ~ ... fa ''''n 

Of "'illylXlllrol ... erdylhM 0'01111 PHV .x.'ebpnnt. ... fa Ihr POV dndlpooUlmd) 

rtetr.t HQS iIspecOOns or il!ptna. • _ \lI"iIf:m ~ rtqIlRd by • gcromnmai 

e,d~ 

15) MO\int T o-W"" l\) 

Tho I>llW ~ j:fCl1Xs PlIAs .. ill IIJ.IIIIber of .. v.-m of ~ oflhr 1)nied Sw:s 

IbIsq: AcI of 1937 designed 10 t.:~ ap:ie$ ~. thtir opaI:m be)IlIlCI ... -ba "''1$ 

uhorimIlI QHWllA, A$ HUD cIesried ill ls report. ~ mi!un(t 1U'ipied. popdIlilDll't 

D.lI hd~ IDII dilKml nmls 1m)' Iqill 10 be bell 1M by small ~tmms II 

~lln IDII ~ of !he resptClr.t j:IIlplI or ~ MIl\' .,.as my 

~ I ....... of regubtms II1II they may IIso do:l' H~ proctdnI rtqIlitm:m 

111hri- disl;retoo. to :otkvi:lle lIdrnmiltnl~l: tudens m 'or 10 bener xm: local reeds. lI\JD's rtpon 

Iiso tied PHAs repor1~ thalldministmM: !l!~n11lMg ~~ed II ~ rIlionll or rrcW!gfu1 

UIIi! of nJl'tm," .h ".wd!U!T 11V)r.Iit- and rnidellillndOOi .~fk1iJq ... illlIr HA." 

Be)oniI 00Il ""i-p. ~t1W<nabIcd Idrninistnlilt "'~ hi't ~ IIr .. ~ 11111 PHA$ furr;tlln. 
144 


MtW agencies' pt1CIim m I good SOUftt 1C m abo\I the l)'PC'S of rcgIlwory and adrri1istza1~"t 

burdm; of ... hich to rtlievt 0\' modifY non-M1W agencies. 

Coofam:e Corrmittt Repon (House ~ 111·366) 1C the "T ranspon.Iioo I HUD COlI.IOlid:altd 

Awofrialions Act 2010' (p.L 111·111)!ttCS. "Of the furds 1IWfernd, n:JIle\s !Iun S45.000.000 

is br [«1IIic.a1 assistaru. Fulliing is . 1so ..,l;lable for r=th, evail:«ms and deroonsmIioos. Th: 

wnl'mes direct HUD to conduct an (l'lklalioo of the Mo\'ing to Wor\;; ~im prognm. 1C l:e 

~1eI(() b)' Augusl31, 20111" In ~ of20IG.HUD issuIola!tpOll to CMgms tikd. "Mol'i1g 

to Work: llU!in Policy Applic.a!ions aIlI the fUUR of the DrncllSlratioo." NAHRO is seekatg 

clarifa1ioo from the Dt!U'Irrrrt :!bout "kther iI vr,.,~ the !tpOII iIsucd to the ~ in August 

2OIOz wisfying the ronfmes ditttil'e in House Rqlort I I I .3U. 

Willi the mqllm of I ftll' i1tmS such IS inprol'tl1Xll.l 10 th: ,xli"eIY of limied English 

ProfICiency. not all MtW agencies lit likelylO brnef. in the samo: "1)' IS non-MtW agm:ies from 

in1!~ma1a!OO of rcgIlla!ory aIlI admini$trali\~ rtlicf. NAHRO ... auk! lik. to explore ... ttl [he 

Dtparuntra aIlI ~flW agenciesareas of adrnflistza1~"t rtlicffor participat~ agencies. 

Pagot3d26 
145 


t1 "'~t: 'i NAHRO 

" "u1I1MDll-lmproving OpportniCIe! 

---b" lncrmed Ongoing Adlllillistr:o.ti,'t Fee 

Rtl-tIl"""itbjp f.listing 1U$oI!~ 

I) A~t Dim.1 AjlpIopria~"" Adminill:rati.-. r"" wid! ExiItBrg Apprupriat!d FWKI:s. 

Pmni PHi\> to obw moniwllilt fees. ~ ~~'RA nu .mer Seru.1n 8(q) b- each &may !hit 

!oases successfully kim Nd. ~ HAP Assds (NRA) ~ tilt" 0Urt :mlIIfS 1ft a\!ilablo: fi'om 

Dtttmbcr] I, 2010 IIId jrilr)em ESlixlitahnh Ifnlrislln appIical* IOP.L. 1I1·38hti:!l oues: 

.• 1'ruWtJ finher, That (rk Im:vtf //We arai/ohk writr this puagraph In insI/fide,. kI 

{XIj1ht ~ deIomMed IMr lilt P'f'w /rtlIi1I.lh! ~m:P) ohmI!e IhtIJllllR.< 

~ .. agtII('ie!"byQ"""'~rwliaHt/l)allf1/1nrifjrl'Cti\"illgfininglftier 

this ~ (r 1II;l)', /() Iht tJ:1nI ~ .. f'OI'ide fi/l paymtrl if am?UIWl ~ 

..m IN pnm fMw, lIiIizt l#IOhIigaed Ixi<n:u. indrQing ~ arrJ \Ul)QWr:!, 

~fink~/OrheDtpmmmifHt=ngOl!d~lJew/opImIlnkr 

rhis ~/« jisai JftF 2009 mi,.,u fo«i)t'<n, /llfII~ lhe fUp03tl for IliIki! 

~ ~ \!fIt'~' Pn:MJtdfwther, 1hat _ pvo:U!d Iftierthis fX'I'8"Pt 

sJdJ /It ~ P 0CfMtiu rrbed '" Ih f'1lI~ rf _.fxrstd rrrtd .m:isIm;r iU~ 

..w. Jtdion& mrdnglrlted<he/opmetl ruiWitJ,',._ 

E.xm:i\mg the bo\~ administntive f« provision in the Aa lhat t""bk, HUD to all\lll' PHAs to 

use (btu unobligated NRA fuMs from prior)'W' to iro:rease ongoing a.dministrali"~ f« pr0-

rations would help the HeV program sustain lhi: numb!'r of families sm\'d Ia51 r and 

facilitate the Departrro:llI acro~ish in g ~ FY 2010·FY 201) SlrIIlegic Plan goa~ 

Z) lmmedia~ Mmum to AIlc\iat. FiaoaciaJ.OO Adminillratirt Slraias ReialiDg (0 HUD', 

EIisling Oftl bj~~' S~ltem (2 ~ CFR § 98lJSJ). 

\\'~ ~iat. tilt" DqlIItme .. 's inliati\( on poItabiliy rdoon ill Mh 2010, as lId as 

)000' il,'llh'emct1 ofPHAs in! PHA iJ.lum) ~' 'deas on IhG in1portaI1 JrogIWllIml. 

On lilly 27, 2010, NAHRO subm.'ud to HUD PlH ourvamsi>"( rdonn m.vmrnerdati.)ns 

~ 

'wing to !be portability feature of the HCV progr3IIl. Alii:",!: 0Iller ~ NAHRO 

regulatory and odrMiltrtlr.( rdorm:s ... 000:1 rtduct bil ling and administnl:i, .. 

<ms bel.Wtell PHAs. Acceimtq the ru km&\;ir€ prIl(eS! ;, Ih~ ~ ... rult taki"@ the 

fulb\o.-ng IIft\llI'e5 "'"OIIkI bt mJSt apprtciated by ~H O end _ PHA II"I!mhm. 

Arrong Other problt.m, ongoing odminiMti,"( fm; for porublt ,oucht!1 arc based on 80 

percent of the -Colrmm 8" rate for the reter."ing PHA" and 20 ptfunl of !he "ColwM 8" ,",Ie 
146 


for inii.al PHA, prio: to tile national pro-fllion percent being 'ppl;e,j. ''CQlIunn B

n fee "lOS 

pro.KIt less flf1/l!'l;ial co~nsalion to FHA! than "'Column A: ~ ·'Column B" fee " te is 7.0 

of tile but I",o-bedroom fMR from 19931I99~, and tile "Column An rale is 7.S ptretnt of the 

bue two-«droom FMR from 199311994. As a rt$\Ilt. !:otIL ;"Iial and re.:e;"ing PHAs of all 

1~l"'S (i.e. c~)". coumy. nru~~cowllY and st31r) idmmisL«ing voumrn through ponability 

billings. txperirntt higbrr admi'li5Ll1ti,·c rom than usual ~l rtecr.t substantially It$s fees. for 

PHA! with porubiliy billings, NAHRO ftt(IllUtIroos as a trmp0r3ry and panial fIX that HuD 

\1St an 80% ",. 20% ;plil of tile "'CoLmn A" adminiSlfllr.t' fee m~ 10 moft. ll<leqLl3ttly 

romprnsate these agencies. Vt!thin tile QJIlle\l of a ~hensi"r ponability policy tMt 

balances the intmst1 oflU FHAs includmg iniLial and m:eiving PHA$, NAHRO belie\'tS it is 

imprralWc for the Depanmrnt 10 mo,t forward in ItI expedil"'l1$ I'lIsh"'n so that tilt 80% vSo 

2W. SJllit of ongoing Il<lministratil'e fees belWetll agencies re.:e~ ing 78.5 annual pro-ral'r::ln is 

CO"lllete~ remedied immediatel)·, 

3) Rtrolldliatiolt of PIIAs' 10ft Rcsukrtd HAP AueI$, Ua restricltd Nfl AsSfIS lad 

CUIla,"tSI1IIftI1$. 

NAHRO ~s HUD = is enor ill Is wroiesale usc oHIC data in 2009, by ~;"g 

PHAs' 1'10:\ ~ HAP MIeIs {NRA~ U!mllicltd Net MIeIs (UNA) an:l CasIl1n''eSltnms, 

1t5~ VMS dati fur ,w:m Ieas~ and COSIS. It is our W"r.:Imtarilq that earlitr Ihi:s )W HUO has 

~ t/x$c: rewncili:l!ixts for all but a itII·1tm!rnI PHAs and plan! 10 CIlfl1l,"e Ihi:s process fo! 

the renWning PHA! adnmisuring SccOOn 8 !erurl·based mueller P'ogt'3IlII i1 the near MUfI:. Our 

~ioohas~mlelemetts: 

ri lr PHAf Nfl RHtric!ed lIAP Aml . mounl$. Man~ PHAs bm signifltllnl 

NRA d3crtpancies co~ ""ith the amounts identifKd for them by HUD in prtviClus 

)'to/'$, HUO·\ O'*S$tI\tnL of some PH""" NRA is , ignif"'ontly night! lhan :oct.,lly 

exiru. This had the effttt of w"l'Ounding the impact ~f d~l!ibu1iClnal sronf.11s to many 

PHA~ arouoo the rounuy. by Ovtrst.aling a primary sourct offuRlina - NRA· no:w.wy 

10 dral ... ith them. In 2009, HUD and Congress toot extraonii~ u !iClll$ 10 belp 

remtdy fuRling shonfllils for PHAs facing lmninaling flmilies, "hieh took place in 

W!l~ me3.Rll't due to IlUO·s ",tIolesale Ult of PIC da!.l rather than VMS dala for "mj<J. 

monlh" lruing. Then> are other PHAs that experienced limding shonhlls due 10 the 

Sime HUD error, ... 00 roWel not lease turro,'er >'O\IChrn and endtd up s:tn'ing f(",CI' 

fami lies and had no financial ~medy, As a resuk ofHUD's em>r, PHAs wm forced [g 

use fe"'eT familitlth.ln t/x. rouil have Olberwise seM!!. NAHRO m:ommenols HUD 

m:aku\a1c PHAs' proptr No:\ kstrictod IVJ' Assets (NRA) using VMS Ua!.l I!Id 

reimburse tIxse PHAs for 1I1lOUllIS O"'~ w\lilt cominuing 10 saltsf)-' !be mo milliln 

rescission (olf>fl) Ia!gt! mancblod in the FY 2(1(l9 approprialioralC!. \\F«ooLJ! any Ilt"" 

appropriations and tntnly within the existing amourts of!\RA nal ......... ide. NAHRO 

reoommtOOS HlJD ftC3ltulatc PHAs' prop« NRA usinS VMS d~1 and ill accordance 

with PIH NOIicc 2009-13. Inslta\!. it ~ppem that HUD's FY 2012 budget plans [g 

ctment its inaccurate assessment and off>fl of PHAs' NRA, by ''Miing tbe caps" in 

PHAf Anollal Conlrihu!ion CoIlU'aClS (ACCs) and aIlO""ing the 1Ia,ts" to sme gre~ er 
147 


~ of funil~ than thti" ACC -m k'-rl and tilt "hI't-DOU" 10 im-r bnfamilies than thti" ACC YOUCber It~L 

RKOacilt !'HAs' UamllYtrd liet Autt "_alS. MIn)'!'HM ha'~sigr1iflC&l1l UNA 

discrtpanc:ie3 co~ w~h the "",",unli idtocifird for them by HUD;" pre"jogs ~nrs. 

NAHRO rtCOmmo:nds HUD realculate PHAs' UNA prolX"'iy. 

RKl)IIcilr !'HAs' C~~~va!1IIftI 1J. Many PHAI bro,'e lian;f~ discl'tplllCie3 ;" 

Lll:i" CMllII\'n!1IE1"lS ~ ","ill the amolltS i:lm:iflCd lOr u.:m by HUD in 

pm"ioII$)'WS. NAHRO ~ HUD rm.klllIu !'HAs' Caslr.111\"rSl/IIe1lI5 

""""'. 

ReaIn:III!e PHAs' .ou.er IrasfotIp "..J hdgrt: Itiliutioa nlttlllSil, VMS datI, 10 

lUke IU It tloot '.'Y Irt i. I.e corl"f(f 11ililarioa lroups. BlSI!d on HUD's I\"holtsalt 

use of PIC dw. for PHA$" "mid·mofllh" leasing ratiln" than VMS datI, Jo/nI: PHAI" 

l'OU(iIn" bsing and budge! !lil~iIn Illes should be rtC~ifoed IS pro.i,1ed in HUD 

NOIiec 20()9.) J. If CO!J1Ilttrd, Ibis .,wld .lfttl the g\,;ulation of PH As' NRA offSCIS. 

4) hap",,'c M~' lot Dmrmil~ !'HAs' EIigibiity b" Heller ,wllio.i!ltmil1· rl'l! 

Ratti ((24 CfR 19I115?{bXJjI. 

In makq is rmtr,g &:!mniIaIm. HUD uses P!iAs' .ililr.I~ fey t:q:m1tS m.i>1: 10 I 

theoretDi Idnmislrali\~ fee wnrv 1I1~ • , 100 pn>rti:ln p.=nI ~ IhIn ~ ... 11I!he 

.:tllli ~lln 1Or.bt1 gim> year. As. rewll'HAs' wro \\\lIl1l OIllcno.iIc: ~)ify uo:.ler tht 

fflqlIiIn ftc rtgU~'cn [{24 n"R i 982.IS2{bX3)1 =rt <b:1ml ineligiblt by HUD. NAHRO 

rtroII"IIk'I"Ii thtI tht )}qlartmttt n:'\'ic\r.' etiplle PitAs· awlUtiJns ill- v;cq:AiIn fee 1lI~ by 

o;oo,,,*'.IIl:~ odmftiImc;.~ kc ..... notS .. JI, tht __ ~ rcu fotlhl ~,... 

5} Allow !'HAs 10 illlplHaHI Mlm! ' 'ole.r. I'll)" .. , SfI..Jlrdl ;. I IDOft IiIHIy 

CaPioII (24 OR§ 93L51ll). 

PitAs only cam Qngoin& adminislll1i,~ fees b ~lICh ,,,ueilCNSSistrd family un.Icr ItlSf. 

Sif:nir>e1ll1 ItUmbrn of Public llousir1 A~no;irs' (PHA» wound the coWll!)' Ia,'e insuff>eient 

HAP ful"Kll to )calf up to the~ iGjusted baklino: number of authorized I'luelkn. In additi;m, 

PHM had sianifX:1I11 amounI$ oftiltir I'tt Rntric1ed HAP AIICIS (NItA) offici from tJx:m aM 

lIIi1iztd signifnll amounts of!!ri NCI Rntrit!rd HAP AsJc(s il2009. CUtmt~:!hm is 

IIOIhq 011 the hDrimn I{j repitnish ~ or an of their Net ~rd HAP A$$m. Thil 

lI'dtnnioes I~ PHM'lbiliy 10 lI'II)(im~ wi" ongMf: _itistr1Ii,-e fee ~ and 

pIIIiNlarly ",tit ongoinc ldmiIislmivr fee pro-raliw It 7I.S pcmN: 1\ NIL Thi! "" ~I 

suNl)" urdmninr HeV propn ~Iiarn and ~ 1tI"~ COll\lr.litU on Ihe~ abilities 

to sem l'Imilirs and property O\\TIt!$, 

NAHRO belirvcslhat !hi: "iIIenl ofHUD requ~ing !'HA! under existinSlfgubtion. to implement 

11o",·n't4l'lymrnlllandard III howhold', scrond re-eumirwion ofhousehold IlEmbm aM 

~, "'"IS 10 ,1Iow for 1111'0 )~II trwiion &om !he IIltf&CI" date ofOmbcr I. 1999 of the: 
148 


lDrlleJ "'''' (RIS 2Sn-AB91) F'emrc Ibr comolDlioll of thr Sedioa I CMifitlle Dl 

~ Seaion 8 \Weber propn! (24 eFR § 148 e: aL). H!J,\'e\u, sm !he rn:miiol! 10 

eo~kIc the: maJeI" of bolh pnlpIfIS m;kd II)' Onobn- I, 2001, thil pranEr of.'uit, UIlIil 

!be tfOOn.:I ho~holi:! rfrnIminalion m\'IUu it pbc:. II 1 sipifoclll lqlm!t Ie l~ Hev 

program lniJ rc..,~ tlilliMe Io,,·ineome familn being :;m~, 

To ~Ip proviX some InW\lI'l' of fllllllCial ltlicflO lbose PHAs within exmina approprialN 

F~. WOIIkI be CoogrtS$ rtqIIiing Hue 10 cxmisc Ks .:Ust~ rqublOl)' lIIlhony (2 ~ cn § 

~). NAHltO 1ttOIIlIller.h Conptss ditcl HUD 10 redul:e l~ o:um:D: tme &ames 

rtq.Ii'ed of Public Housint: Afm::ie$' (!'HAs) 10 impIomtrl ~ .oucm pI.)'mcnlllmllnh 

(CfR 9I250S) iom bousthokh' second lftDIIIimtiln to tbr gnaa of 9IJ.doys iom w date 

!be hcwdIoki is rolifled or a housdIOld',' Imc i\M;"crwy dale. 

IIUD am:ised Ks aWoriy.ilh llx issuance of PIH 2OOS,911111lhrough substqIoc:!1IlICIions. 

bill PHAs Ioo ~ to implement !honer lime frames I'm !heir Io\\t!<:d p.!)'11IC1Il 51andards hm 

been rtqUired by ~ Dep&rtmont lQ go lhrollgh " Ml lTIIIly belicl1: sMuld be III ~CffiB)' 

IM*nscme "'Iil'r! proms. Funhmnort, in order for !'HAs 10 11m their wlil'r! rt'QUOSlS 

"+'P"Oved in 200~ IIIId be,ond. HUO lIB reqllRd wm agmriol 10 /lOt ~iwr lumo,U 

voudIers 10 eligiIle applicants or Ieue thom up Inh Ibr propant 1Il/D', rxistirt polic) 

rTUleS ~ i;Jr qm:ie$ thIl needed .1i>U "+'P"O, .. t b stmcned 1_~ i;Jr tfrio 

pI)lIVlII $IZIdatd ~ ill order 10 _Ibr _ ... mber of rxislinl families or 10 mtort 

Ibri Imina 10 previoM lel'ebor ttn adjusted Ace bastlint nurnba' of ,'CI.d!cn, 

Whrn lt an: OOio:l ing mar\;ets " hich lie ,ooimg loll 50 long "' I PIIA's ltgtllltory 

"a fferdability sca.ndard" is mel 12. CFR 19S2.l02{eK1Kiiil), llkmi: l~ lixne IllWU!e ,,~uld 

proli;le oppol1ll/liln Ie mncdy l~ir 19Cn;n' fund ing shonf.aJls wlhin tlx existing HAP 

_ f"O"iIIod. buI ..... ik- IlOl irnpoI~ btds/1¥ (WI ...... ;,."."".. farnil;" oro! partioi(la1ina 

propmY""lIm. Thl! IIIW\I't COIIId ~~ _ !'HAs mitigate !he eff~ of oo...l\'II'lnI proIII(d adnWI;su.i> .. fen. if!lxy an: abIr to bcnu \Il~~ tbe~ ,,'libble HAP and NRA mourm 

10 inmue \be nambcr offunslies thry least, up 10 their adjuSlfd bDtlinr JaIInbrT of VOIKbm. 

5) IWnslile oppomail)' for ltalPOrlry lad parti:al 1t'llDlr" of IlAP " d,,, 1.I'orily lid 

'O\I~b"" bmr_ PIlAI(PIII NMitt 2002·14} 

Pre\ioI3Iy PHAs that hid IPllt IIAP flmdm, lhm C(luld :;moe 100 permit of ~ir lUlhorited 

VOIKhm, wvrted wll> un.:It.-furded PIiAs il their ~ ~ies (wl/lit the same 

rneuopolilJn IrtI, IIMHnetropelUn COU/IY, Of iiUk) to I'OkuuriIy tnnsf., I ponioa of Ihcir 

HAP Iulgn IIlho!iy IIIId 1'OIdIen (pm No!i::e 1OO2 ~ This proms .flioll rtqUi'ed PHAs' 

lIOIif~ai.ln to HUO, enabled 1fUIr! IaUIIber of low-mwt t7amilie$ to be !IIf\~ Illd aho 

fltilUted. ~ meIbod b!lOlllt COIMIWliirl dulilg "ith. liP Iw!q marut to rttti>'e 

the ~ fimdil'lg to IkIJ "'M tempoIII)' spikes in thoir HAP casu. HUO'! prtVWs rotice 

enabled PHA!! to lmISfr!!Ix same lIPJlDII of HAP bu;!gtt lutmrly baek to I~ original PHA! 

JUCh lhat 111 agencn rtUined lheir lOla.! number of ILIlhorized \'01ICher1:, 1I0""' r!. m MardI 7, 

2007, HUD issuro I OOlEr (PIli 2007~l ftSCindin8 PHAsluthoTt)' for pt.rtial ~fr! ofHAl' 

IlJdat1 ~horiI ~ ar.:I instead only 11o"~ PHA! dil'61 tbtir mire \1IUtha pIOg'Im to anotil!!' 
149 


PHA Of /Ill HAl' Iimd~ II all. Undtr IIUO's 20011QiIx, .. IIKh I'Oklrwy YObi;M- progm 

di'~~ ... pemIIIIMI. whic:h b &II ittnts ml JUl'IOStS, ~bXd PHAs IRIpVtg ttn 

unJer,/Unded nrighllomg ~ies iIIId w f.tmilies they im'f, NAHRO I'fCOmmmb 

I'finsultmi:~ ofPIH Noxic:t 2002,14 r& tm)uglI re inmt~ luthoci)' 10 PHAs Of ptO,idinB 

similar lutOOrit~ to HUO Fic:1d and'or R~ionI! Off~, This mml.lrt woold lIa'e tho benrr' of 

m.aximiu IVJib.bk HAP rellOun:n to 5(1'\'r tho maximum ... mber of families "hik , Iso 

potentially rnabliDg I vester ptrtentqt' of PHAs !o UI~itt I ponicm of thoir Nri Res!rJ:tai HAP 

AISeli if ,,·.illbk 10 augment thoi cqor., admili5mti\'r ffe, pro-!IIio!Is urd:r (11.1" rln! ~ionabo\-c. 

IMq w glmQx ~. HUD IIMnrcd ~ ~'f fm 10 PHAs buN on thei pm 

tued \'OUCbm. wilh recon;ili;l!;ions to ~ tolTl'iM! on I rolling bIsis rtIfNd~t IC tholqmils of 

ekh )tw, HUD ilfornxd PitAs tIw they I'ftded 10 tmUIt t!llt tho LOlli ~ furMls tOr 

~ adminilullh'f fm art d~ed ~ ~ taknd. )taI'lleasrc dllotA lIlY QVtf·fundin& 

or !nIrr·fundrc. \\'lIaI"'f IIIlII' knew, bI5fd on the IzsI ~ calm:!ar)~ of~ is that 

~ 

HUD's ~ "tokl!.d;" II the em of exh ynrllll bten umm:ssriy ut'nsilt. The orcoq; 

fee am:urs I'HA.$ .. ~ Id .. ij, ~ Ibesr "tokl '-i" p:rW:s brI'l: boer! »til 

tbo-ot Ih: anum .. tlri utimllt c.1rn11r )_ JIIII"IIIln. NAmO I'mIIIIIImIh thai do: 

~ gqe a IIIIlI'f ~ "IIokI bId:~ b' Deamber 2011 iIIId be)on:I thai ill!IJCb.cb$\s 

lC .. tm the fnI e&ImIar 'jf:ll Jro'lIIion illblylO be. !'HAs ~1DJr!r HUO's IinalltoJlXuillion 

oftlri ~ 2010 ~ tanini!ml~'f ftc pro-~ IC IR\:I t/'tm o;opt "ill thei 2011 0;\1$ 

il ftc I'f''mn In add'lion, Ih: 5r\m)' of HUO's adnlmiltralivr fee dhOOldirrg iI 2011 and 

be)ond coukI ~ miigated in. rumber Of"'l)'$. 

Fr.,!lUD Ndd I"Y "",sore~ ...... b no ...... 1lm 100 P""ftlofead! PHA', 

IUduiz:cd I'OIdm obq the Q)WX of the )QI'. Oirmdy. HUD JII)1 b IIIIlIIbIy 0\a'0sq; 

~ the }Q'..c~ flllll reconcilillion iJr Ikcmt<:r. 

SototJi NAt!RO'uw.t '«Ot","".Pt.ilI: lhi1g !'HAs 1C t.:ook iI VMS ~ thai is 

r.)I OOIIlrd ..c~ WI (Of I doed;) is XIIIlIy ItttToW iIIId Iiousq AssisIIm: Pa)m::1t (HAP) 

expetI!eS art ooIlX>\lIIed o.n~ they lit Il'UIaIly paid. ",m reduct 1'fIlOItt~. po$lirl Qf Uni ,\.1ormi 

Leased (UMul b)' !'HAs ~ oonsilmbk pcri;lm of!me IS is row the tISC. As I rtSUk, HUD ... i11 

tor able 10 ~ile PHAs' caleQ )'QI 0110~ ~istrIIr.t f~ Jro'nt.Ons i'I • IIIIlI'f timtl~ 

""'" 

TlWII. NAHItO m»rIIOO'd$ dill HUO _ PHAs' Sf.MAP asq and tu¥ llilmIiIn 

(lndicatof 11) 00 I aIm;br.)W bail IIIher dan I PHA 1isaJ.)Q' bmis 1l1li toIIIIUIOIt this 

e:o:p/id: chqe to PlIA$ iI 'Iori:~ Thii has betn uroXr ronsiXnIion II IIIr [)qarumI b. my 

kq tine. PIH ~ ~1 suu.:L "HUD "ilI_ furt!o:r iUidanct I'fla~ 10 IIIr Yc:ar·EtJI 

~lemm S!aemcIU v.'hidt. ~ 1C the b:iI: quaM' .. It.: cali:rda' year 2005. "'ill ~ l:wd 

011 calm.:!at }'t1tS mher than I PHII's flSUl )'rat mj," 8¢caIIOe- this prooedln IDs IIIlI tc 

irqllemmcd b calm.:!at J'tIIr1 2006-2009, J&C!o:Lcs!ll .... bettl it lh: dIIrl'r>'iabIc posilion ofha'ing 

1C IIIIXimizt lh: IIlC of tIrT limdq; to Ii:u:: 'IJIdom tIrt>ugIo th: crwl oflhc:i r~ )'<111 iIIId then 
150 


itd~Org is nectssary !Or !he cakrdv )tWo Agm:ics fate\l",ilh bsj,g ""lbin !her bastline by PHA 

flStl! ~ willen cakrdv )~ may, because !hey have an in3rdequate amollll of lime 10 make 

iIOJj.tstme1lS 1(1 de3I",lh !her funding sronfalls, dnmatnlly 1311'4' !her leasing up or do"'n bejtlod 

!he rates !he)' OIIJm<isc I'IWkI ifbs~ and 1:..:Ig(! Ulilizmg b)' tm.iar )til" only. Add in !he b.:to< 

of appropri!tions bill$ becoming law ronsidmbly .fter Septeml:er J(} ea:h year, aM Ihe rrtd 10 

aUe\1a1e!'HAs Ifom th~ unntCes>aI)'oonstrtirl beccmes mrt cot1'4XlIiIg. The mu_ir€ benef,s thai. 

\\\?UkI incP..de mrt oonsi:ster1 rates ofbsilg during Ihe ca'mlar )tar !Or ~ of more rtliable 

Of'€'lilg .dminisl!at~'e fee p;Q-rlIIions, NAHRO has also ~~ed thai !he Departmer1 = thai 

agm:ics art 001 penalized wlb bI'ItT SSMAP StOrt$ b)' tas~ soorili: on Ihe hiP oflheir f!SCIl 

ytat or calendar )t3r bsilg and I:..:Igtt !4il@:llR. and similarly thall!1t Departmer1 ~ thai. 

agm:ics 11ft no! pauliztd in lher application stOrtS ror incmno:.ul ,wchers 
151 


~Ji !i NAHRO 

AnlclulltIIll· Ballnciq 

---

!IIpn)l~",15 of IIUD'IIAionulioll eclo~ 5yJlnlll 

.. j ill Oaroial Adllilliltnlin Fie rind;'&; Jlllp<'O'ia, HUO'J IItplllOfy r rmf«<lrt. 

OIpmrioll ad o.micbt ~ lDd HUD'J HeY Adatiai51l'1lire FI'r SNd)' 

I) f l'll:dL'rorr..ds r"'lII SfttioIIIAccoI:ll1o HUD', T'Ulfor.ariotl l.ililliH rotNnl 

Gftl'l'lliolt \'oatH. MlllItmtIIl S)llftll (NG\'MS) IIId lilt WatkilE Capital r.od. 

HUO'I fin·)"tir Transformation Inlillivt (TI) plan pI'IlplSCS to IUt th.$e fund<! for IIfte 

t(lmp~nwy purposes: I) rtsurtll. t\'IJu3l1;m .nd program mt1rics: 2) !I'\ly.1m 

delllOll$UJliQns; aro:! 3) l«iYlitll mi:!Uocc and ~ily bu ild ina. Tlkina II taIIl or$! 13 millien 

Oil of the Sttlion I attO\IIt fer HUO', muh)'w NtXl GtnmIion ~m M~ 

System (NGVMS) ...J FHA IT JySIeIIIS projcru. dvori the amounI of 1IIOIIe)' thai wne out of 

the SectioA IIttOIIIII ;" jftl'ious )fIf1 ill' I!J: I\'orkillg CIIpUI Fund. For n:arJlIle.1ht FY 2009 

~ A;ipropNtiomAa jIIO'I'iIkd noIlIIDI'r than S1.9 milliollifom the Slaiod • a.:tOIIII. '" 

the \\OrtDcClrpPJ Ful'i In FY20IIl. HUD r=nNom IIrof"urod. ha"l_'swonhofthe 

l)picalll'ftlll fundilg fimmIy prowidN 10 !lie I\'O!\ing Caput Fund. HUO'I FY 2012 tulget 

. S96 million tnnlfn" from the Smion I TmanI·!lncd IIrnlUIII for NGVMS lS .. d IS 

addi:iorlll funding of $241 milli;ln from tht Woding Caplal fund for the lkrclopment, 

~ralion and maimentnCe of infomlllion tethnology (In Iystem! that !illppon Depanmm.al 

progtam$lnd opmIKlm, COlt rll\ltM:iallnd leotra.i ~ims. 

While,,~ .ro.o'A1I:dge th:: ~ \0 irI:ipro\-.: INO'sIT 5)'IICml. arri .. ing a.1lrl1m:ed ~ 

~ 

in fundq; IUdI impul~ and fund" ~ dtm ~ Dr!he StctDil, p!OpII \0 pl!ti:ipan:1 

th:: ~ _ in oo!cr. \\'c bc:1icI-.: .llo"Ain& mort funds \0 mIIIin in thr Scailn 

I Itl:OWII in FY 2011 10 bc:1p i:npfoot ~ AlS~ h)'ll'lm fu..:linjlnd IqOirt 

ICiminisualin fcc pro-~i;w 'l'ililldp 1CCO!Illiish Ihts equally ~ pl. Thts ts no! !he 

time 10 dio-.:n IW'tt m:ourm from lilt trilicilly imponan! NrxlDn thIt PHA stiffs deli.'try of 

smiceslC klw· trxome families. 

Will tlII: beq 5Wd, NAHRO n CIII' PHA memberslul"t proI'ided a1msive I7.OIl'IW.IS 10 HUD's 

Ltam repdq: ~ ~ urdcr tbI: NGVMS projcu. Iu ~ of HUO'I 

.,.~ TIIIISbmatila IlIiillil-.: and I'(iVMS pajtd. a ~ IIIIIrIIand i thr IND tam is 

Iookqa VMS I5""Ualllofthrltlllcd iIbmWJn 5)-tt.I i lhouti ilmafllal'n" .. u 

~DIIr. iltWll, PIC, fDS, fASS. BY a 'Adla fnID'J progmI flwaionmcssmm; 

5)1Ietr111h SEM."J', ~ op:~tooI. mooIt PHA rist·1UtSSImI ~<:IC. Wt al!o 

InImlmd that INO is Dtmted in kam~ al:oIlihr "1IImiII ilerfaoe" wih VMS and oW: HUD 

IT 1}$ItmS in • tCl'I¥\'l"tns~ ~ " .. ay 50 lbII th: ~ e~ prog!a/II1IIII~ i\'i.iarn to is 

PHA pwm ilr rmrt ICCIIrIlt mllllil'orm daillIilmissions. Am:lnC NAH RO's JI:COIlI1X1ldatDns 

submiledlO HUD PIH on Math 7, 2011 inc:We t.d ftnDIlimled 10: I) ~ PICtothe pm. 
152 


offull fitntti:mtrty I!Id rrodify. so !hot I: ~ be IIStd IS the ~is filr PHAs' flM!):~1 d~ 

like HUD's in1egraud Muti-Family A= ElIdl!J1g~ (MAX) ill SeciiHI 8 Projtt1&1ed ~M~ 

famjly Rtrtal Alsislanct prognrns; 2) Il1rovt !he data usro II PIC and VMS 50 tInI PitAs gel 100 

;ertm ~ I!Id in t l~ly fashiHI foI'!heir!lC'! HAP dof.: ;: .~ rtSlJ~"' from W 

plIIabiJiy fnmn of the HeV ~ Rcimbo.i~mm: R>r PHM !IC'! p;nubilly HAP ddiel: 

expense is Ii.: only Urn II all ofHUO's HAP calcuwioo; filr PHAs !hal. art lill bastd 011 PIC data 

ratla than on VMS data; 3) com« kmia:d f.:lds filr m ~iflt ''QU;1a program (i.e. HlII). 

VASIl, ruP, I_~ MaO!sumn.OIt,)50thaucanle infl)lll'DlDnsuch lSNRA can be sui:mlted to 

HlJI) and properly ISsessed by the Depa/tInoII; 4) U.IC I check the box S}'$l~ to a<;QJ1In! filr \(lUCia 

jZ\lgI3II'lIldminis1md by each PHA and bbck 0lA ~Iicable VMS fields to mlIa:t the _ of 

!We I!Id errors wocialed wib w CIJITtII ohign; mI S) ~ one s;.mm (PIC Of VMS) to capturt 

IoOOCIm issued ~ Ihin asking i;)r this inbm:llion in I;oth S)'lIaros and u.sing inoonsiSlem 

dol'rili:>~ 0) M narnined w actual ar.l C'U/I'tI1I HUD m:thod IS rclIr:n~ in PHAs' \W'tIt PIC 

OoJinqllmc)' Repoos. CIitm!y, PHAs thai \I~ to "'I~' ~urt the n.cessary l'I ~rmaliHI in 

order !O l'tCQ!l("ile ther P1C I!Id VMS rqlM~ 10 HUD. havt 10 use infunrut'oo \)'leM thai. art 

auxiliary to HUD's Delinqueocy Rrport In detmninin@ PIC reponing .. ~ II.: denDminirtor HUD is 

u.s~ II.: IIlmlxr of leased '1)lIChcri in PHAs' mo5! <emf Il))I'IIh of VMS dala sutxnimd (l._ 

/':o.trnm- 30, 2010) II.: PIC data 6lrnm the ImSI <emf m:JI'lh submllc:d by the !.1Sl Frida)' of that 

@i,tnll"Cl1th(i.e. Docm-IJa 31. 2010), NAHRD r=mrnm.ls HUD Il!e II.: sarr.e time pa'od R>r 

roth PIC II1I.I VMS filr HlJI)'se'llllali:mofPHA>' PIC ....... ning /aI~; 7) the "'Pon (Mj" f.:Jd in the 

o.~y Repon tJas I hel of,roblell"ll"that "QUid be$! be fIXed rrogmrrna!ally by HUD PIH 

tInM.igh the-/IIlrrnaking process. Ho .. '!\tf. thm ~ III inhom'I problem wlh hlial PHAs that havt 

pxubiliy bmings \lib =ivilg ag.:/"iOO that art ~nI on m:riving 'Pies lOr thei PIC 

~ing rates; 8) iIlw'ovt 00lh th: propnming thresMkIs ar.:I the fi'tqum;y ofHUD Fiel:l Off~ 

saaffirlerfatmg wib th:.'bard 011'"' re,'jew &rol '1Ilmtlln prom:Iwhich was jIlSI made .. me duri"€ 

the April 1011 release; II1I.I9) P1C ~!O.,,;i!t Mo"q-to-Work agm:ios. 

PIC in ls >IITtIt Sl3Ie is challrngillg I!Id lim: roIIlIIJ1ling. PHAs need to submi llo!«IDkl data 

tIrough HUD's PIC S}'SlCm. PHAs toD:rstard !he caootpt and the Fclml Govtmmat's need br II 

Iwt sorrto of this itformation. UnkinWl3lely. the PIC ~= Ii'eqoelily will not acctpt do ww.. 

reporting iI as I lillal error.jM;;"br!y .. hen PHAs submi historical oo)l!ilmOnt~ PHAs art wimut 

IIppro~ialely cquiwol HUD SIaff /C!OUICeS 10 resol> .. PIC probI<!I>\" .. ~h imJllCl the accuracy of 

PIC daIa, and art tim: OOIl.I1.Iming and C09.Iy b- PHA and HlJI) saaff in !he adminiSlmDn of the 

program. During , <emf mcdin¥ .. ill HUD Regional ao:I HQ saaffPHAi \1m: oot.'i$ed that lhete is 

I backlog of om 250 ~Jt ordm to in1p\orne!t comctive acti:lns 10 PIC soa..W't that n.-.. not been 

add=ed to dxe. HUD's Regional Ofl"~ peoomel art great ~ MlAI!O "Ilrl: \lib. Th~y act as 

re3SOllIbie p2MetS in the adrninistraOOn oft!.: Stttion S .00th!r JI"OSITIE- UJOOnumldy, Regilnal 

Off.:es arc powerless 10 addre:ss Fttano;ial issues !lemming from PIC IIlll \'1I1S-re1a1011 JWObIerm that 

PHAs~ .... 

2) Cornd mnbodologrfn'Orsin ~""btin, PIIM' PIC reportiD! /\Ila 

In Oo:tobcr 2007 ao:IlaIer again in Scptcmbcr 2008, NAHRO raisel .!jlfCiflC qucstiorll. "'ib HUD 

about Ii.: Depanm:ra's lII3lI.:mat:ieal eakulati.ms in dtterm!!ing PHM P1C reponing /ales wib 

thtir cormponding VMS data from lhe sarr.e ~ tim: peri:Id tnkI PIH ~i:t 2007-29. 
153 


Todlle.li'c~aplanDJnorHl.lD'$~ro~ I'HA$' PIC~IRS in 

IhiIwe p!O\'ik ilsulfm 4euilI1IIIl lick Ii'c Jr.d of ~ _f tltliM is _'IIJIIUd. 

UrmoMd probtms ... -1II PIC aro:I VMS ~ I/w:: QJ!trd ofPHAs. ~I 1III't ad'I'~ ~ .... m: 

b thrm n.:ludq: 

I) ~-mna PHA!' Seo:1iln Elgie Mwgmm ASSCI.SIl'm Propam (WoW) $(QIt$ tIt\.1 .... 

... taI thry §/mild tit if HUD's IT 1)*""1 aro:I Hun PlH JX'li!JIIl!ttl!' t\'JkIa!ions ... ae 

pabm:d in ~ ... 'e 11UD'1 fI\~.egulaWns.Idi:es...:l guidm;e; 

bj ~ PHAs'ldrniIiIInlM fcc ~ pamftldy b _ '/o'ijJ PIC rqutilg IRS 

tltlow94's pm:M; 

t) 1l!II.1;.:.mg Pfl.ol,s b Raul J~ ~kIniorq (1U~1) nI RMII HouU:t Iruui) 1~ mrnI Propn{RIUIP) firdilp: ml 

e) eliminal~ SCxh parrncile Flir Ma"ket ReI'I5 (FMRs) b ~I n»Mm'~.w,\\'OO: 

(Mtw) PHA.\' ~IIM JUtiII:oJ 11m III1lII'td I/w:: ttVIl)'. 

Gi>'tI! lilt ... ide rqc of~ on PItA! reu_ile &om un PIC ~ I'RI n:bDt; fnmIl 

1IMi:nI...:I pabmIrre IISmIIXIlIIItII$, NAHRO ItIllI'IIIImIs ~o.:.ion ofl/w:: Dq:.urm'1 

tlkullliJm in oolalO JIO''ik ptr~. A okwlrd o.plnIilnorfl"Olllm!s idtttifitd 

b HUO" NAHRO<an tit b.nt on pages 111_ 21 OU" lenalO HUDon N.Ir4" 2OlI. 

3) ComtI PIC S)5f\'m KI be Comlitnt ,,~b 1M SlallUf &I RIt¥liIIlio.u GoI'tnIiIIg 1'HAs' 

AftftuaJ IIOS InspttIioli Rtquil'tmfllll (24 ern 982 4OS( Il~ 

PH'" lit "'I"M prirm Hous~ Qualil)' SurdIrd (HQS) ~ nf!hoi- 'oOIIdrr-aMtd 

d$ "IInIalI)'" okfrltd.ll_ ill:p«:tion _ per calmIa-)Q". 

If'IJD '-raade ~elli'llIS 10 II N*: and Ind ... flcuq InilrrraIlII CerIa (PIC) 0Ift I/w:: 

yars IIaI albro'S b I broader rarer of ....... x.k" naaI iIspcC1ion dIIa mmd do PIC. HlJ[Y1 

PIC ~'SIem ~ In IIlIIIIl .1i."1r1 dale ro tit ~ ... lhi'! hoOl"It.lfdII bc:bl: or aIier I/w:: 

dale of ea:h l'OOtheHl"sisKd IrJu:olehclfs prt\"'I.lus ItnIII i'Isptt1m. mha!lun on:e :uruaUps is 

~iW \lrQenh: I'tgUmions. Th: t<ml"t lId!ninis!ralil-t l'tIf.'itrrtll! as -. rflates 111 PIC ard PHA'I 

5«OOn Et/I Mwgtmm AISesSrrt:!II (SEMAP) 5CIlrir& ruth:!- !han tIIIder tIJi: UU!e an;! 

teglllllion!.. ~Ifnlbbn. 

Trtdimlty,/'HA's nuaI ~ con:idt ... i:k cxh lelll,fJ m.)\~" daIe,"'hid! ~ mt 

alb .... b ~ fteUliJiy 10 ~ HQS i6pectilm popphic:alty. E_en .. iII lilt 

~_ in PIC (~ 1b:M) PHAs lit flI)I afbdtd I/w:: kft! olfte:dliliy a'Id efr-.:im:ies 

enjoyed b)' MQI'ilg-lO-WIrl: .,..:it-s!hlll tIoukI be a.2iIIbIe 10 rm-MtW lFCies 'IIW tIJi: 

nisl".wocy rtqIImncn.1IaI PllAs ftpmed,QIICber-asWo1iNs 1rftIaI1y, 1~"1h: 

cod", ill PIC fwther 10 ~w PHAI &raICI" fltxillill}' KI cklsler .IOm ~11y or by 

mu_Hamily dII"tUinj] IIIIi br ~Ie, woul:l JIO"i;Ie .rQlt I'tli:rto PHAs "Ib ~I;on 
154 


!tilled ~,d tlpCIIItS art .at. priullrly ... ih!be pm of po_ nI PIiAs opa1I~ in 

apmsiI"f pisdimm 

Undtr ~~isling~· m.I rtgIIlluioI!. p~ sh:Iuld be allo ... ed 10 (hoose Ilinx full .... l(l <OrJloct 

WIIIlI inspettilns lhat f( !bei' Iocll ~s .. ilhin ~~isling 1131U1ory des~n inl:1~n8 boil 1"0)1 

limited 10: geogrilp/lit IIlU, muk~ famil~ dcvelopmem.lease anni,crsary, CU:, 

4) IIUD Repblory FI'IlIIl'II'ort lad lWMIsidentiol of Its OrpaiDl;o. .. d Onnigbl 

Many -PIIAJ ~ UbI br!be ~e luden 01'l1li: pubIie ~ lflii HCV propns-IIII: 

IIft'Ct!Iri)'CCIII1'lex ~ of~mI promlns has aukd 11IuiI0n"'h:R' PHAs 60 Ill! 

tw,,'t IWIIJJmy ova ~ adminiltra!ild nI wuklildap a jWpIIS IG Ii bal needL MM'I)' 

PHA offieialJ fm the eMtSi& rtgulalill'l kI be mbli!art.~"f 10 bal hovs~ nwktu, 

nI iI;oosillm ... iII bal needs. 

The Oepctmm mHoolq and l/rbul [)e'"fbpnm. has.;.stly or ¥1y.1xtn rrxnIly cnj:iD::d in 

_ ~ b M'I o'~m proc:t5I rorr¢ara. !be ~ ~ peri;Irmanct m:I in 

r-aI b failiIg kI QIIY Qlj b IIIission dlC!(Ii¥e~, Bodi::s _h 11ft NainI Acaikmy ofPubk 

~1111 an! the Milkmial Hoasq: CoomiWxI lII,c otre;ed cn~ arrl 

ItcOIIIU(I .... 1I1. lOIn: of ... -him hro"f!w:rn m 1IpOO.!u lIIIII)'of .. hil:h III.! lID!. 

HUD PO.tR has ~Ieicd "'1l .... "f)1 on !be hel of 5IlilfaciOn ""iII HUD and is p-ogrmm b)' 

II'II:ITtItn of IlfIPIOxirnaiely rigIw: HUD pwtner gzoups. which Wtlt Sla'\'t)ed in 2001 m:I 2006. lisled 

bebw i$ HUD'slUlMW)' ofPI{As' mponse$ frIlm!be 2006 fK!blicalOn, 

HlJDPD.lR ""P_,~,""HUD',P~ MiI:~As-YP"""," " -""" 

~~ , 

~~ 

:r""" ... ""'~ .. . , 
155 


Time ,corrmitm:", 1\) ~Iy ",ilh I 

!'WI!!!!! 

A l\III0' pwoer 1II'\-e,' b:, f'I.)llt tIa idIdes _ of lIE samr pWotr ~ "i1 ~i;k 

5UlistiaDy II!rid C$lintles ofa.rm SilisflKlm IMIs mI rsliNIe ~ iI SIIisfklm Ie\'tis 

~;.p, 2006.. Th: rtpOI1's .IC!Jedabl completion dalt is May 2011. We art anxious to scc: lbe otSI)ks of 

!his SIIW)' OIU pub!ishco.! mI bo/( iJr"lI1llO ~ 'Iiilll )011 abo\.t "ha "lS lcIrncd millie 

Oqatmm:'I ~ "lrJlIltpi" illigIl of!h: ~'s FY 2010 ~ FY 201S ~ Plan 

coak ilckld,,1'rwbm dJt WI)' HUD Docs lluiilm.· 

At • tirrt llhen afbdabIc bwsing ncoJs Ir.:I tilt anmcbnl r~ial <k:mar4s on tilt rtdetal 

f)I'MII!Im. ~ ~ iI is aoo: ~ tI.... f\(f thai HtlD Iin:OOn tl'l'«l;"dy IIld IlII1 it 

rna:Umizt the 1M of U ~ NAHRO btlit>~ IlII1 • ~t __ m oftht 

Dq.nmm'1 OIpIlilllimJI II/V;ItI't and is Olmplpp'OlclllS II awosDte br Ibt new 

Adminiwailft -top 10 bc:tIom. This!'tC'Wllilatiln!hJo.ill not lit lim~a:I LO mili!lrllil .. IIJ:ISU't$ 

1hit II$SIlm: no thange ilIIUD'~ lUlhorizila Iq:islam mI it slJcKjkl lit c:ondocIa:I ",ill as mu:h 

Ira!!pImq 

~ 

IIld !IIbIi: .. as ~. AIIa:t;:" 10 JW:tJ.nI ~ion i/'ioukl lit 

II)' I .:oosidcnlioII "bcth!r ft ~ mI rtgIIllIory "nitin-" :II dJt 

Dtp.umt, "hich 1m siplifhllly wihil the orpnizaIiJn III .. IlIIt, ad,'JII;CS or IIirdm HUD 

iI ilCJtitIo" is miss"'n fll'dllhal. if 1I\),hilg.$h)ukl be 00ne aboo.I it, 

NAHRO is no! IIIt.q: IQ ,,110 >uggt!l the aIloli;:" of w DtpwnM Il I cDltI,le\~ 

dtp;wMt. We do tuggtst 1111: 

Th: .rove mtIlind ~;:., of Ib:: Dq.nmm's ~ional i\IIId.1I'I: aOO 

O\'mCIao:ubR!DlWlbt~asll.lOdll~, 

AI\a'I;:" shlIIld lit pW 10 milimilil& rtgIIllIory IIld Idm~ ~ms mI 

harm::>nil;ilg .egulalol)' rtgints appliclbk 10 srniJar lC1;"iit1 pmxm.n.: mmumnens 

.elllilc 10 the ~ inI opmti::ICI of real e!Ult !hJu1d 10 Ib:: OlCli ~ bt 

~ ionI f\u.i.:n of ~ic rtglliaory or DniIisIIaIiI .. poass «JI!'CIiiara, 

RquIllOl)' rrilrm WIll;! bt an IJ<I1Ili1 ~ • HUO, 1I"hid! iMllITs poOldic 

considmliJn crib:: tgRpe (I\~ dmIan<k made upon I'HA! and OllIe! btitia. Th: 

IkpwrrTl shoo);! eonsida' tamg tit q.qnIUIII of rtglllaIory im.,asir.," en rill SIIIlIIa 

P»As ~ b5 riIk (froancial ...... i$e) 10 the ftdmI SO'mrnmI and shoold 1hari:II't ~ 

I ~ rquiIIoIy scheme. 

IIUD shau);! _ I mJ:\\~ wrm'Ilmm LO "'" ~ of ~ 'Iiilh <tgU'aItd 

tftbes $11th as I'l~ IIMh ~ out lIE fiUD ~ This p;:uniaUy imll,es many 

1hircs. Iu ilcklda:i IIroIt tb::rn lIIOOId lit I IMIt .w.. and pm inull_ of 

~ pnn Ml pac!' II1IIljWtIIC)' 11ft pocns of dndJpils 1IIidara. rtglllI:ion. 

IIld ltgisIaIiI"t IWP*Is. 

Tht ~ shaul;! ~ it ... ob/C:!I;:" LO sedt lIE fllllMal ~ n=sary U 

!'HAs...soWr ~'aItd Min ID arI)' "" irs ~ If tIJo:M ItSOImS arm! ~ 
156 


oIuftd ~ ""~ in Ih:: obIipm; at rtpIlIIcd (!!Iii=! 5/oifd br 1IliIIIr. In 

.. -m.. ~ _1hII1h:: ~ 5tet to adtie'o'f I ~ p!Op)I'IioraIi) betMtft th: 

oIP/iplilm ~ ~ rqullud ~ " th: ~ supplied 10 rnceI tIw 

-

11l¥O''f roonloring ...:I OI'el1ig!'t of ~ agenci=! wih de~ed program 

~ .. h:retlq~ ll\lIy.rilkofg<>i"c no ·'UOUbIed" ilIIus. The 

~m ofth: Soxti:ln II'OIICM propn is Ucady ~ ~ Raul HtMq; 

Irtcwiy I~ I'ropn (RHI P~ Irtcwir ~ (Rf).l}1n51t ~"ftl, 

SE..\\AP oonfl"lllllCl)'on-Ut mlrool, iIdcpmIM IUdh, n m:ds b)' HUD', f_ill 

~tngaam: Ccrur. n MTC5. All of!lw:se m-ns mpZt lIIdiior.! I'HA lUfI"tirE in 

"flat is amdy I lUff iIm$t.'f propn opera" ",ih l'0III0, .. mb-1iJr5 in 

ldmiIiltrM~'f ftt~ 

The ~ .. Ins irtemaJ risk,assessmert databases to I1IC "lIen.r. on'ltt audls. ~ !'HAs .. ruch IIlmil1 i1uf 80 pcran! of .1I1'OIdm r.!1JrM"U WlIu.,~ /tCti .. td rrukip~ 

HUD llIIIis ova 1Ir ItsI ~mf )-c.n hI,~ been StIf¥o:t 10 HUD', addiicr.1 "ronsolidutd 

~;e..,.- HUD·, ~ ~J. ha,~ I3lm ~ ""ih PllAs " ih3Il th:r mr 

III,· ... ~i .. td Ih:: .esub of pm.i:Ju!; OII-Ut HUD ~M 10 It.: my ~ p'llbIemI idalifItd coul.:l to: ~ if~. ~ mruftS ~ nmXd. 10 _ SIft It.: 

PlIAs ~ r(lt ~ 10 • IIIIkiplitiy of OIHic visa b 6.f1icar.t ~ The ~ofllr lIlIu is ~ VoIp". To _!"r.) pr!IIOOl!ortnnlpml ~ of 

~ ill" tim: -...fts lII.t b«n pro,.ided. 

While II. acknowledge t/"at t'-: [)ql.vuml has the rigl't (II1II oblipticn) to wrdua 

~ ClmighI X!r.·i ies,.so .. efl.so I mardalt 10 m!UIT It. is diu J)"SIerrtS roruII 

-* <Iou. VI'< klit.~ IlioI i aloo ""' Ibt obIipion 10 MIduoIIhI>to acti<iit< iI ... 

dTlCien: _dut_Qs~..:f CIU'le§lIr leu dinpllnofPHA 1Clft"ii=s,. Its 

obIPion in Ihii ~ is IIIh:: II1CR K\I(" . I tim "lEa tim ~ ba ~ 

a>"Ii!abIe to 1m. S«tion. families. 

5) HUD'I MCV Progralll Admiaislrlriu FetStwly. 

Durq: se,m.1 ~ HUD offICial! Slid dut «lS n Stdi:Jn , terart-bued ~ PfOgnms' 

~ admin_~'f fm \M)I,II.:I halt" 11\ • 00 PHA5 and 1IUI ITt ~·5 HCV program 

adminiItraM fee ;tp:!)· .. ooid ha~ 10 be fmIII5iXm1 ~ .. It iI 011" 1I"derItInd~ thai HUD 

PD&R. is CIITt1lfy in ITt l"tOJInisswu IDJ br\HcsIlie P- ortht swdy. NAHRO "'f~ Ih:: 

opp;lI\lIIiy IOdi!I;w do: q.:t ofCY 201 1 or.,q ~ Sec ~ 011 H\ID·I HCV 

p!QpI! m.inisuai>t it !ltdy. 
157 


!Ii' "' t:'lli NAHRO 

--- In Jdd.ioo co 0\1' regulalOr}' and idmnistnlr.-e ftWIIYIImiatilns. listed btklw is NAHRO'I 

newly m:olNtltnded Ieg~*i ,t ~ giving thr IIUO SecITlll)' W llnhol'ily Ie waivr 11'1« 

spC'dflt Section • l~'bascd >'OUdIer staWlr)' requmr-s 1fPII!q:: I) _I ~ 

Qua~r $w1dard itsptcti::lrJl; 2) _I IKMchoId =ifio;.ioos IIId 1) ml I'nSOOIbItnm 

dnmninations u tht DqwtnYlll dclmn;!ItS is rltCnsary!O redu« admini$tralil'e rtqUftmtM$ 

.. 'hen oogo~ Idminisl~i\f ftc;s lit pm-nI<:d btlo,,' 90 pl'r«nI. \I~ In: pro"idinS this 

~ to )'011 ito the hope till! the ~ will !ttk "id __ tIwaaJh 1M 

idtrJIir"'l!on ofa "iabk kgislali.-C' ,'chil:lc. 

SiC _ Mn~ CRY. (nil"'" t( law, f iht Stmtwy t( IkItaitrg and UioM 

Dtwlcpmt.- dtlmlriN$ ~ tkl iitt _ tfftnfmg II\wlobIt 10 public IrorGing agm:itsp 

COJtJatdoptmaof~~rt"~ ..... Sttflloo8cflitt tRrittd 

San ~ Au of /9J1 {lilt "M "' dinrg drt edt.)It(F IOIIQI IK 1m ... 9I)pMffI 

of/Itt _ iJ'II''idtd ill srrfiooo 8(f} of/Itt'/<1 <II & ~ iINntdialIy"optr 10 Ihr t_rt 

of 1M QUiIy 1/IJIDing and N'Ori litJpMsihiiily Act of 1998 (f'L 105 .. 176. ]I. 1998) . 

... 1htS«rrrtr,""'Y-b/.NtI~ tffmiw~IOa6{1111!1itNillg~ 

~J>dIrmo/~""IIIgIO""'_II'a(}nt(.""'lIIgrtqlll1f_· 

(a) tllIIAd "''ltWJ of ft.i!}· u.:-~ 10 $ilbstclioll8(o)(5) of 1M UIIi'H SllIIfS 

IIoMWrtMtt( 19]7; 

(b) AIIIIWI ir!.!p«1ioM of lllliu punlOtl 10 swbstcIkM 8~}~)(D} of Iitt Ulliltd Slim 

rmmng Ad of 1m; and 

«:) RtrrI I'NI/IIIIIhItwu alkwiatlllfU f"I'-* 10 .IIIbJra"", 8(o)(/(I)(A) of iIIt Vrrifd 

SlIlttJ Hotaillf AC10119J7. 

Jf4l'>m iswtdpwRll1M 10 dIiJ JeCtlOllsltoJl lot SJJhjM 10 J>ri ~ and tfform"p SIdr ",""",/Jfdtt~" __ 
158 

LETTER FROM THE PRESERVATION WORKING GROUP 


PRESERVATION WORKING GROUP 

July3l.20]2 

Ch~lrman Raben M~nende% 

Ran):;illgMem~ lim DeMint 

Sen.te Banking Comml1let 

Subromm'tn~eon HOlISm!;. 

Trdn,poruliC)fl ilnd COinmunity Dn"e!opmtnt 

5H Olrkm Sc~te OlfletBulldl1ll 

1'I'3ihlnglM,0<:20510 

!lfar Chillnnan Me/ltndel3nd Rill,king Member DeMin~ 

Thank you fur holding this ,mponanl hearing utltd, ·Stream~n\ng ilnd 

Strtngtluming HUO's Rental .m!5tanct Pnlgran\S.· Tht ~hon Working Cro"~ 

>lrullgly supports rh.t/lges to HUOs rtntal.rulstanl,'t progralll$ thai will make them more 

~rncient and effrnive for housln~ ~perators. developers ilnd tEnants, We Il'SpeClfully 

request Ihat yOlllndude this leuetln the hearing record. 

The PIl'SE,\'alion Working Gro~p iJ' ooaillion of non·profit housing develOpfl1, o\Vnrr~. 

Statt and loa! hOllsmg agenaes aid tenanll Militated III ItIt prest'MtJon of exmtl\jl 

I'tdtrany assist~ affordable houutg, W. JI'I' supportive or rh.JngfS th.il WIU redlXE costs 

10 hll\ll tlUD and housing operalOIS, but als~ h~lp ITl'lte and presl'rve th! aV3ibbillt) of 

.ffi!rdilblt hou~it>g tD low·inrome nGmehoJds. 

TIlt House SubcommiuH on Inrur.anno, Houslng and Community Opporlunlty I>a.I 

milf"ktd up the AifOrdlhlc HOU5ln! and 5elfSuffitlenl'y Improvement An (AHSSA), Inn 

indudes many provlSi~ns that ... e luppon Induding mudlrlCltions 10 the prvject·bas.d 

l'Oucher program. suumlinmg till F.unily Self Suffidtnc), I'rogr.Im aDd providing kmg· 

to"" ren!<li us!:itlnre Cllnluns \( propenles wllb no option to rEncw e~lSlIng «IWart.f. 

In additwn, the bill strumJines uTit inspecllQns and simplifies renl and inQlme 

I"OIlrulati~ns ... hid! art rommon sense d!angts that will redlKt dupliCiltM1 admtnistr.au ..... e 

b\lrdens and SI\'t critical staff tim! fDr hOUSIng pl"OVldm. 

The ,hanges that AHSSA makes II> me Projea·8.\sed VOllmer (P8V) progr.am wtll gIVe 

Public HouslngAUlhonuts (PHAsJ more HexiblUty to serve ~t·risk populations. servt' more 

1000Inmme f.mjlies In rtlr~1 romtlunlUes illJd prtMde more affurdable hooslng optlllns In 

hiJh-((lstdrta5. The PBV progr.tm. jikt tI\e Prolert·based Section a program, enables 

..... nel"! II> leverdge the lon~·term rontr.lct 1<1 rehabilitate exlSltng properties or moall' 

mi:!I~d·inrornl' hDusing. This progr.lm hal IIdn rttogniztd btlth by HUD dnd Crmgress an 

Imporunt preS<'rV~t!on too! lh~t suppgn~ irn:ome-ml~ing aMlepment and amnecl$ 

tenants to JUPpon.ive servia:s. AHSSA's changes to the PBV program further thtse ''''0 
159 


PRESERVATION WORKING GROUP 

gGolls. We also encoul'llge the. Commitlo:>e 10 OO!ISlder making two additional ch~ng~s \0 the 

P6V program to help PHAs preserve existing hUlI'llng .lUd pn:v~n\ displatcement of lowIncome lenaOI5. 

Exempt public housing revltallz:lIiOQ from COUlltlog again.u the PHA projectbase ,'Oueller cap. Currently. PHAs are limited to project·b~slflg 20% orlbetr 

vouchtr funds. Unrortunat~ly, this limitation rn.lkes It more Mlkulr for a PHA to 

revitalize public howling developmenl.'i in In~ch nred of capilli rl'palr tlIJ( ~I't not 

sllitabte for pilrtitipalion in HUD's Rental AssIStance DemunslIatlOn (RAD] program, 

Making lhi~ liml!ed ~ct tion will prtll'ide a cntical ddilional tool to PHAs who 

o!'l'd il by glVI"g them greater ne~ ili y to managt' their voudt~r prtlgroms In a way 

that leverllges private capital to make ovemue capital repairs. 

Enable the project-basing of leD~nt protection vouchers. Tenanl pmtecuoo 

l'IIurnm (T1'Vs1 are I:>SUro by HUD Ie Wn3nts in properties where<1Wn~rs IIpt OU! 

of (eJlta) aS$;sunC!' contracts, tilt u~ ar a(fordablhty rt>StM.:tlons l'lCplre ()r th~ 

rental assl~net rontrart C!1ds. Currently. HUt> has limited authorlty to pmiertbase TPVs for a subst:1 of prtlpMies. Expanding thiS authonty 10 all unilS that will r~ve TPVs helps malnYln atfordabillty for low-income households. preVI:ntt 

tenant displacement and iUPPUrts recap!lali'zatiel1 of the property. 

Th~$j' too.'o !I(IoCllSt dlilnges will SUPP<lrt LIIe preservation of community assets and 

pltl!1'CI theSlgnificant il1vestment Ihe feder.ll goVt'l'lItnen! has already made in these 

pro~nie~. 

Wtapiliaud this Sulx:Qmmi\l~ fer hllMng thi~ h~aring. We look forward to 

working with )'OU al\d your House counterparts to move wese l!nponanlll'forms 

fOl'W:1rd, 

Sincrrely. 

~lIrorola H~\I$In~ P~rtnersbip 

EFI\iljl Adlten~rg. HOllSlng Policy and Development CO!tsultanl 

tnlerpn.le Community Partners 

IndtngAge 

LooIII nillatives Support Corporatlon 

MTM Consyiting u.c, Affordable HOlUmg Finance alld Preservalloll 

N~tlonal HOUSing LilwProject 

National Hou&iog Tru~1 

National Low Inl"QmeHl)Ilslng Cool ilion 

Nelwork for Oregon Amm ab ~ Hou$ln~ 

!'reservation or Affol'llab1c Housing. Inc 

Merry KD ~ing. Inc. 

SIev.'ards oJ Alforrlabte Hcusing for tlJe Fuwl'f' 
160 

LETTER TO THE SENATE BANKING COMMITTEE REGARDING SECTION 

8 VOUCHER REFORM 


Tne HOI'IOIable!lOllM Ueoe!IOez 

"'" Senale ~ HOIJsrr>g ~I'IG U_ Allin CCI1mII~ 

Sub<;ormwee.,., HoUSlll!J TlinsportlllOn, ~nd CoImu1lty Oevalopment 

W.!iJIrlgIon. DC 20151 

Thl! Honorable Jim OIl""'! 

RaflkmljlMO"ller 

Sorl;llr e.~ IiCIIB"9In1i Um." ~ff .. C«!mUee S"~.,., i10uStng Tra)1S/)O/!.lUOll and C<lll"m.llllty OI!Il'I!iDI>metIt 

y.,'ul6n\jlon DC 10151 

Ou, ChaimlIn Me11fffiodellna Ran.k~ MenUt OIlMlnt 

Thrllil tI!a1l 'n!k!soy II pleilsed INt)'Oll are!iokSf,g I h!lflOg Ie I~S SecwJ 8 'IOUd)tr 

reltwm. o..t ir;;k)sllY belltl'H ~ II in1:mi~ for CorIgreSlI~ Pili ~ Ihat \'011 improI'C IIlf 

\'OIIdltr ~iRllo' be1l'l fU~1S lid CWIIe1'$Iki;,e: laMg Ia~r doll." and eIitMI1n9 

inebnoe'i are I must Wt ~tIPPO"1l11o COIIi:ePIl "'IIIiIOied ~ !he Di~'" 0riI1 Grille 

AIIon1lble Iiousllg ~d se~.sullieitll~ III'JI,IIOveme11t Ad 0[2012 ~Io\~ approWd by II'Ie ~ 

rmartail Ser<lcel Hoosrlg SubcMmliet !1M, tills rur 

Q,jrorvanlZOliOOl "PflI500t_ra lIIi!f1~ ccn~f'"es lendlrs . WIden ;nO tIe~5 arid 

h~uiIDg agenoes We h..., foIIg-l\WIrte<I 11& S~ 8 l1CIUSIflII Cl!otce VtouCllef~, 1'111101 

1lfI)>IOi!I re~ i!JiI5IOies 10 iPprox!ITIHely t..o ~ very-lcw ~ Ilouse~k!s 'Mto 00IaiIT 

nOUSMl\l fl ll1e PIVi" rental maml The progriIfI\ 'III'IICh II inMflded to broidtn till '1'lgI 01 

hllU5rrIg dlooces to< i;lmioel ",,~,~ 0I>J5tIg, 11;11 prOven to (:Ie.~ ., MtP"'lllIow 

_ IimoIieI find decont, ure 100 I~Qfdab'.I'M>.Js.ng. In ~ !he oa11l1t.oochera 0:111_ till 

!I!\'eIlgod III noild oewor,"""~I. eiliWIQ afIornablil MI"SO"g, , nllU""Y "1odIi1 tioj.,t mlIaI 

mafl"el$. 

IiowI!l'IIf. ill Spit at' III owfBI WOO!5I, !he I'DI.dIIr program lUIIen under Ihe weigIIt 01100 l\1IlIy 

.. elfdult afld duplcaM requiremer>ts Th! I!I'fOId ovtr\ap(Jlng IIIId I'IoIbIcIim ~s h.i~ 

madr the PIQQIlIm ~ to idrTwIbt<.Jfld ~ rtIIIIy pro/enooallirdorol from psrtklp,llng 

in IIIe (1(OpTl M such, WI! hil'l -wot;ed diigenty ~ Coo~lt fDt leWfIl yurs flOW 10 OmJIilI 

corrrnatI $e1lSo! l!gIStsoonlO ~t/'!'\fI'IiM 1M HOlIsmg CI'IOiGe VOUCI1er PrDgram, 

We SI.WM lI1e AHSSIA I:IiI beat<se I redLiCU !axp;yer !:CSis..ct\It me Oepartmenl oflious.,g 

i'lClllrtliln Oel'llopmenrl (/'IUD) ~n1IIII'ICUIlf'lg progi'lmlind IICIIII;IIU greater povale seclOf 

p,lrl/QpatlOtl .. l~llIe 1Iao1l/lg. ~ ~ part 01 tus ellOIl to< Millie varIOUS ~rrts 

111_ IS tie ~tml'lllrlrtg 01 ffdrfll~9Iliallons . SlfenWnllg lI1e ~m \Oil re&Jc.r 

~1lr3",e 0ISden11lld klwef ptOfllll !:Cst!, ~ flctU5IIlg local ~tily nus ill tum ... 

mean IIlIIIIYlN ov.oers .... 'MInt to ".roopate in dllli've!i'rg ilford~ 1IOO11f'91O tOOse wIto need ~ 

Nolal'll1lile F'(W13 fl\JD ~ reqJrSlI many srmNr pnMSIOfIS 10 'lie tbJSII ~f\. 'Ihdr ClI~ 

liltltarrtlal snt!VI O!I ApnI28, 2011 HUD ~tiIY [Ionoqn leltfiert befort lI1f; Senate 

BWrrog HOU15'11\1. ~d UIW1I All..,. Cclnmhee, ""d I~ maII't of ~ rek>rm!., tne ti:>u5eOrdu ·",,,,,,,,,,e .... • 

We "'VIto ",~t.evetlll prolUw<tl of p;ifIJOJiI<' sq;"tb"CI! lMI we .U~., ttv. f\elM I:rilI 

1100 tne:rlIItaQ!IlI1e Sena!! 10 </\dude IhHe prlMSIOOI " lulu ... pIOPOIolls 
161 


Slfeanmnir.g the Property Inspotction Proc.n. fot AHSSIA ililows tloollOQ aultton1ei 

Ie "erform unit ~IO!IS every other y~lr rattler lI1~n ~u~ aIId .Jnw\I(eS lilt nt~ for 

dopllc.lttva ~ns. ~ currenlly occur lIIlen 3 propeftJ'is lJnar.ced ~ mulliple 

governmenl hOlf!if\g pr!)!pIIl$ weh as fH,I. mortgage ;nwlll~~.law InCOfl"8 f"Ioosirl9 Ta~ 

Credol$ (LIHTDl) 0< fIOI.tE. Mu~ "trlSlll'dPO!I f8qJlI'lIments increase operabng =15 Ie 

prop.lftJ' <)M1e~ an4 caU!~ sgnifil:ant IIICOnlot/!lellte 10 tenants anti 3Ie not r1ete»!l1)' to 

ensure good qlla~1J mailllBll3r>:.e 

Secorld. the Id pernvts JTrneaiate tenanl oc:co~ ij lIle unit tIiI~ been "~pe(\ed 'Mthlll 

lIle past fnr ~nd h IorlDiI.lhere are 110 !(~lhre"IIfI~19 eoniflioni". nilS Is tnpOlWIl kif 

bolh teOilOts iIld owners iI!iio.e because. redIJces lIle ~gI~ ofline ~ II!lJIIS VICifII alld 

ibM; tenanlS to II"IO\le into the oo~ ~!IIotll detay 

Simplijyiog Rem .rod Income C.kulaoons. His P!1M5t1l11 i~ntly redouces 

amn"slrnve burdens ~ aIovMg lor 1111 recm!icawn of I"9flI aodi/to:lll"Oll to OCCI,II"evel)' 

DUlle years raltter lhan ilnooilly lor lhose on fIlced lo:>corMi aod allows del!ll"lI"ioatioos made 

lor ollie( federal meanHested prowant! to be u~ III the veril\ca~n process l~ilnfI, 

iI1es& eilaoges \\i4j ilP$lIy 10 a~ rental aSs<Slana ana other HUD as5'5led houl,"g ~a"'5, 

no! JUst II1e IOiIdler progwn. 

Reducl~ CosU~ limite~ English Profie[fllCr (UP) Translation Burde!1. CIIITrI1II1UD 

Guidel!lles r~ Ih~ Ira_on 01 all '.ur documenlS i/l1C ~ languiIlles AHSSIA 

woold enlure 1/131 HUDls re..pot'ls1illo lor $Ud\ tr3Ilslabo,u ra!her iI1ao pn\l1lle 

o"MlerSlmilllige<li ~a f>1iAs II1o,s !N",natrlg 1M ruJl!oln lor OWIlers ~d UI\!rJ1izlng Ihe 

translation process. Tna prol1StOI" In 11\& oiD eMU~ ~t persons 'MHI ~rn!ea EngMh 

~ 

prolloency ~ ha~e aCl:eSS ICI accurate mJneflls lild lIlal the pro".sion oIlhese 

3rd ,enjoes ill oo~lJeai.e 

flItef\din9 the Contract Term for Ptoject.b.ued Vouel\ers 1t0/ll15 to to Vears. These 

pro";SI0!15"'" r.elp flcifure 1M Ult of projecl-biiSed YOUCI1eJ1ln UThC ~~i The 

r!f11a1 il!bi.id!es prol'lded by wuchm ~ UHTC CMIII!/S mltel !tie need 10 seNe emm!1)/ 

~ hausebold~ Tile IijI also JWOI'IdIIs other tosllltlC.i1 d\irlg!51c tt>e programs Ihal 

IWIlavance housIr19 oppiljtlMles and ease. transaCIJon31 bamers. 

We appllud II\f Senate to/ rmIdiflg !his l\eilOfl9 We ~ ro.v.ard lcl eoIIlniJ.illl 10 '/IOr1< IrlpOthe, a> 

e/forn; I'J address ",", ,HlJe move rorward 

Couflci] for A/Iorda~ ;md IIUIOI HOIIsang 

InsbllJ\e of Real ESLlte ManaQll!menl 

Initilllte lor AIrordilble HOIIsing f>l"nerva~on 

ludi~e 

NatmaI.IJ'fordabie Hoostrlg ManagemenlAsSOClillron 

NatIOnal ~anmem AslocraUQO 

NallOnal Assodation gl AIIMIabir HOllSlO9 LeOOers 

N3IiOI181 Associalion (l/ H""", Buildt,. 

NatIOnal AsloO(l,llr\ll'l of HouSlll!l CoQj:lfl'Jlivu 

NatlOflili AssllO.l\iOl1 01 Reatlof} 

NatIJnaI Leased Hoosang Asaoc:iatio(l 

NalJlOlt MvItr HouStl1g COlll1cH 

cc: Senale Ban.mg. HOIIs"'9 iIIld Lkbarl Af!aus Cocmrittte 

Paglr 2 01 2 
(163) 

STREAMLINING AND STRENGTHENING HUD’S 

RENTAL HOUSING ASSISTANCE PROGRAMS—PART II 

TUESDAY, DECEMBER 11, 2012 

U.S. SENATE, 

COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS, 

Washington, DC. 

The Committee met at 10:31 a.m., in room SD–538, Dirksen Senate Office Building, Hon. Tim Johnson, Chairman of the Committee, presiding. 

OPENING STATEMENT OF CHAIRMAN TIM JOHNSON 

Chairman JOHNSON. I call this hearing to order. 

I would like to welcome the Honorable Sandra Henriquez once 

again to the Committee for a hearing entitled ‘‘Proposals to 

Streamline and Strengthen HUD’s Rental Housing Assistance Programs, Part II.’’ 

Millions of American families struggle every day to afford a roof 

over their heads. Currently, a person with a full-time job needs to 

earn about $18.50 an hour in order to afford a modest, two-bedroom rental at the national average. This is an amount far above 

the minimum wage or the income provided by Supplemental Security Income. 

Affordability is not just a problem in the largest cities in the 

country. The Sioux Falls Housing and Redevelopment Commission, 

for example, has 3,800 families—nearly twice the number the agency currently serves—on the waiting list for housing assistance. 

HUD’s Section 8 Voucher and Public Housing rental assistance 

programs help over 3 million households, including low-income seniors, people with disabilities, and families with children, find safe, 

affordable housing. This assistance is funded by the Federal Government through HUD and delivered locally through a network of 

local and State public housing authorities, or PHAs. 

Despite the vital role these programs play in our national safety 

net, they face a number of challenges. These include complex administrative procedures, aging buildings in need of revitalization, 

and Federal funding constraints that have local agencies struggling 

to do more with less. The strains on local agencies have become so 

difficult some PHAs have turned down HUD–VASH vouchers for 

homeless veterans—or even shut down completely—due to a lack 

of funding to administer the program. 

164 

Given these challenges and the Nation’s fiscal position, it is essential that our Federal programs operate effectively and efficiently. 

Earlier this year, Senator Menendez’s Subcommittee held a hearing to gather stakeholders’ recommendations for improving these 

programs. Many of these focused on commonsense ideas that have 

been considered in both House and Senate Section 8 voucher reform bills in recent years, such as streamlining housing inspection 

schedules, simplifying rent calculations, and improving PHAs’ ability to provide new housing opportunities through the use of projectbased vouchers. Some of these suggestions would also streamline 

processes in HUD’s Section 8 project-based rental assistance programs. 

We have invited Assistant Secretary Henriquez here to share the 

Administration’s recommendations on this important topic. I look 

forward to learning where there may be consensus around commonsense reforms that will strengthen the Section 8 and public 

housing assistance programs for our families, local partners, and 

taxpayers. 

Are there any other Members—— 

Senator REED. That is a good question. 

[Laughter.] 

Chairman JOHNSON. Jack, do you wish to make a brief opening 

statement? 

Senator REED. Mr. Chairman, thank you again for holding this 

hearing. It is very important. Welcome, Madam Secretary, and I 

look forward to your testimony. Thank you. 

Thank you, Mr. Chairman. 

Chairman JOHNSON. Thank you all. And I want to remind my 

colleagues that the record will be open for the next 7 days for opening statements and any other materials they would like to submit. 

Now I will briefly introduce our witness, the Honorable Sandra 

B. Henriquez, Assistant Secretary for Public and Indian Housing at 

the U.S. Department of Housing and Urban Development. In this 

capacity, she has day-to-day oversight of HUD’s public housing and 

Section 8 voucher programs as well as HUD’s Office of Native 

American Programs. 

Assistant Secretary Henriquez, you may proceed with your testimony. 

STATEMENT OF SANDRA B. HENRIQUEZ, ASSISTANT SECRETARY FOR PUBLIC AND INDIAN HOUSING, DEPARTMENT 

OF HOUSING AND URBAN DEVELOPMENT 

Ms. HENRIQUEZ. Thank you and good morning. Chairman Johnson, Ranking Member Shelby, Mr. Reed, and Members of the Committee, I thank you for inviting me here today to testify this morning on opportunities for reform of the Housing Choice Voucher and 

public housing programs. 

The voucher and public housing programs provide critically important housing assistance in communities across the Nation. 

These programs serve extremely poor families, many of whom are 

elderly or disabled. Not surprisingly, with the recent recession, the 

demand for rental assistance has increased. 

165 

HUD recognizes the urgent need to streamline and simplify its 

rental assistance programs in order to reduce the administrative 

burdens on public housing authorities and to increase overall efficiency, while also generating Federal cost savings where possible. 

In light of the persistent demand for deeply affordable rental 

housing, we are also working hard to preserve public housing. My 

testimony today will cover three important approaches: streamlining and simplifying our programs, further reforming the public 

housing oversight structure to strengthen the portfolio, and increasing flexibility to respond to local housing needs. 

There is broad, external consensus among policy experts and 

practitioners for a number of key reforms that will streamline and 

simplify HUD’s rental assistance programs. In its fiscal year 2013 

budget request, HUD put forward a number of reforms around 

which there is consensus, and these include consolidating the 

Voucher and Public Housing Family Self-Sufficiency programs and 

opening eligibility to multifamily residents; enacting a rental policy 

demonstration to test the effectiveness of different policies and encouraging family economic dependents and self-sufficiency, and authorizing biennial inspections for Housing Choice Voucher units to 

reduce administrative and financial burden. We are exploring further streamlining measures that require statutory authority and 

may be worth pursuing in fiscal year 2014. 

Our commitment to streamlining and simplification extends to 

the future of public housing as well. We recognize the importance 

of aligning our oversight structure with basic property management principles. Small public housing authorities view our existing 

oversight structure—known as the ‘‘Public Housing Assessment 

System,’’ or PHAS—as increasingly unworkable. They assert that 

the program is heavy-handed, that small housing authorities pose 

little risk to HUD, and that HUD should, therefore, scale back its 

oversight of small agencies. 

In response to these concerns, we have taken steps to adjust how 

public housing are scored under the system, and we are willing to 

change and consider other changes as well. 

Broader reform that embraces traditional real estate management practices will bring substantial administrative relief to PHAs 

of all sizes, helping to put the public housing portfolio on a more 

solid foundation. Reform of HUD’s oversight structure is the next 

step on the path established nearly a decade ago with the implementation of ‘‘asset management’’—a system where accounting, 

budgeting, funding, and management are performed at the property level rather than the public housing level. 

The Rental Assistance Demonstration, a top priority of this Administration, also known as RAD, addresses the contractual relationship between public housing authorities and HUD. It offers 

participating housing authorities the option to convert to long-term 

project-based Section 8 contracts which will enable them to leverage private investment on terms similar to those available to private property owners participating in HUD’s multifamily programs. 

We expect that RAD will help to reverse the loss of public housing 

units and to preserve the portfolio going forward. 

The Moving to Work Program was authorized in 1996 as a demonstration as well to provide a limited number of housing authoriVerDate Nov 24 2008 09:17 Apr 26, 2013 Jkt 048080 PO 00000 Frm 00169 Fmt 6601 Sfmt 6601 L:\HEARINGS 2012\08-01 & 12-11 HUD S RENTAL HOUSING ASSISTANCE PROGRAMS, 
166 

ties with the statutory and regulatory flexibility to test practices 

that increase cost-effectiveness, reward employment and economic 

independence, and increase housing choices for low-income families. MTW has enabled housing authorities to pioneer innovative 

approaches to serving homeless families, building resident earnings 

and assets, achieving operating cost efficiencies, and leveraging private capital. 

For example, Home Forward, formerly known as the Portland 

Housing Authority, in Portland, Oregon, used project-based vouchers to provide housing to formerly homeless veterans, and the 

building is served by a full-time resident services coordinator, and 

services are provided by the VA program. Flexibility allows Home 

Forward to provide security deposits to veterans using VA supportive housing vouchers as well. 

The Department is pleased that some of our most important 

stakeholders from public housing authorities and low-income housing advocacy communities were able to negotiate through their differences over MTW in order to advance broader Section 8 reform. 

As the Committee crafts its legislation, we hope you will consider 

the stakeholder approach. 

Mr. Chairman, there is an irrefutable need for rental assistance 

in communities across this Nation. At the same time, there is longstanding consensus on a set of reforms that will streamline and 

simplify administration of the Housing Choice Voucher and the 

public housing programs. HUD is committed to improving not only 

the administration of its programs, but its oversight of the public 

housing programs as well, and we look forward to working with the 

Committee and our industry partners to develop a property-based 

oversight structure. 

We also recognize that any expansion of the MTW program must 

be coupled with measures to protect tenants, assure adequate HUD 

oversight, and evaluate results. 

I look forward to your questions. Thank you. 

Chairman JOHNSON. Thank you for your testimony. 

As we begin the questions, I will ask the clerk to put 5 minutes 

on the clock for each Member. 

As I mentioned earlier, PHAs in my State and around the country are struggling to provide services to families given inadequate 

voucher administrative funding. How will the proposals we have 

been discussing here reduce the burdens on PHAs, particularly 

small agencies serving large areas, like those in South Dakota? 

Ms. HENRIQUEZ. That is a good question, and thank you very 

much. Our proposals to streamline and administer also look at the 

options of forming consortia, having smaller agencies band together 

in order to have economies of scale in administering their programs. In addition, we think that there are streamlined opportunities around inspections, around rent certifications that could happen particularly for those families on fixed incomes, and that could 

happen on a less frequent basis because that income change is 

small and is known year after year. 

We also believe that the inspection protocols could move from annual to biennial, particularly in housing authorities where there is 

a known tenant population with less wear and tear on those units, 

which indeed may free up housing authority staff, create effiVerDate Nov 24 2008 09:17 Apr 26, 2013 Jkt 048080 PO 00000 Frm 00170 Fmt 6601 Sfmt 6601 L:\HEARINGS 2012\08-01 & 12-11 HUD S RENTAL HOUSING ASSISTANCE PROGRAMS, 
167 

ciencies, economies, and allow housing authorities to spread their 

precious resources further to serve the populations that are housed 

in those properties. 

Chairman JOHNSON. PHAs in my State have also described their 

difficulties in keeping up with regulatory burdens and paperwork. 

For example, South Dakotans have mentioned that they are often 

asked to submit the same information multiple times. We must obviously find a balance between the need to provide appropriate 

oversight of taxpayer dollars with the needs of agencies, particularly small agencies who have limited staff and funding. 

Are you examining administrative actions that HUD can take to 

reduce burdens on small PHAs? 

Ms. HENRIQUEZ. Yes, we are examining particularly the reporting and regulatory burden on small PHAs, and indeed, we are trying a couple of things in a couple of different areas. 

One, as I said earlier, we want to look at what we can do to 

streamline across the board. 

Two, we are looking at our own data collection systems to make 

sure that we ask for it once, we do not ask for it in duplicative 

ways, and that when we ask for it, it is information that we are 

going to use, not information that we are not. So we want to make 

sure that our data collection is as tight as possible. 

In addition, providing regulatory relief to small agencies in particular, there are some things that we think make totally good 

sense from a property management and a monitoring perspective. 

We want to take those not just for small agencies, but we want to 

take them to scale, because if they are good for small agencies 

doing real estate property management, then they are good for 

other, larger agencies to do that same work as well. 

And there are other issues around regulatory streamlining that 

we would like to talk more with both the Committee and with 

small agencies about what they need to really run their business 

and balance that with what HUD needs for its own monitoring. We 

realize that we need to look at risk and assess risk, and generally 

small housing authorities, if you follow the money, small agencies 

are less riskier propositions than larger housing authorities to get 

the bulk of the HUD dollars. But we want to strike that balance 

and make sure that we are being as effective and efficient with all 

of our stakeholders. 

Chairman JOHNSON. You have recommended increasing the medical deduction used in income and rent calculations from 3 to 10 

percent of income. Previous versions of the Senate’s SEVRA legislation and the AHSSIA bill under discussion in the House Financial 

Services Committee take a broader approach to simplifying income 

and rent calculations. These measures would streamline several deductions in HUD’s complicated income calculations and replace 

them with higher standard deductions. 

Do you support this broader approach to simplifying deductions? 

Ms. HENRIQUEZ. Yes, we do support a broader approach to simplifying. We think that there will be less errors; it will be easier 

for residents to understand the changes; it will be easier for housing authorities’ staff to actually compute and make less mistakes 

in those computations. We also think that there needs to be a balance between standard deductions and—both on standard deducVerDate Nov 24 2008 09:17 Apr 26, 2013 Jkt 048080 PO 00000 Frm 00171 Fmt 6601 Sfmt 6601 L:\HEARINGS 2012\08-01 & 12-11 HUD S RENTAL HOUSING ASSISTANCE PROGRAMS, 
168 

tions and pairing that with any changes in the medical deductions 

so there is a balanced program. This is truly not to harm or cause 

greater cost to be borne by the most economically vulnerable citizens that we house in our programs. 

Chairman JOHNSON. Senator Reed. 

Senator REED. Well, thank you very much, Mr. Chairman, and 

thank you, Madam Secretary. And as you know, one of the consistent themes here both from your Department and from the 

Chairman’s questioning is lowering the dead weight costs, for want 

of a better term, on small public housing authorities. You are trying to do that. 

One issue that has come recently to our attention is that the 

agency always has recognized that in the awarding of FSS grants 

this year, there were some errors. 

Ms. HENRIQUEZ. Correct. 

Senator REED. You are trying to correct those errors. We have a 

housing authority in North Providence that is in that process. And 

this is another sort of example of particularly smaller public housing authorities where, when they have to go back and redo the 

work, et cetera, it just adds to their administrative costs. 

But could you give us sort of some insight as to what happened 

and what are you doing? 

Ms. HENRIQUEZ. Yes, thank you for that question. I sometimes 

refer to it as ‘‘cosmic convergence.’’ There were several things that 

went wrong, and they all went wrong at the same time, and, hence, 

we find ourselves having made a mistake in the award and the calculations for those awards for the Family Self-Sufficiency grants on 

the voucher side. 

As it relates to small housing authorities, or any housing authority that applied under the NOFA earlier this year, we are not asking for a resubmission. We are going to reprocess starting at the 

point where HUD made its first mistake, and that was our data 

pull. 

I want to be very clear. The NOFA, as written, made a point. It 

said: We will do a data pull from our data base that looks at the 

year-long number of families registered under the Family Self-Sufficiency program at any particular housing authority. We will post 

that data on a Web site, and the link is in the NOFA. So if you 

clicked on the NOFA electronically, it automatically took you to 

that posting. 

In addition, we said please check the posting to see the numbers 

we have for your particular housing authority, and the NOFA said 

if you disagreed with that number, could you please then submit 

a supplemental or an ad hoc report to accompany your submission. 

And we used then that submission as the way to calculate the 

funding for those housing authorities that submitted the ad hoc report. 

Even with that, our data pull was a point in time as opposed to 

an entire year, and so it didn’t take into account—you might have 

had a thousand people at the beginning of the year, people graduated during the year, and you are replacing them, and so your 

number is lower at the point of time pull. That was mistake number one. 

169 

So what we are doing is we are asking—in fact, a letter went out 

Friday to all housing authorities that submitted about 750 of them 

that said we will be reprocessing, here is the information, this is 

the reposting, this is where you will find it, please, again, check the 

reposting, pull your own numbers, resubmit, and from that point 

forward we are going to then actually reprocess all of those applications and make the adjustments where people—some people got 

awards that should not have, some people got lower awards, some 

people got higher amounts than they were due. 

When all is said and done, because it is a mistake of the Department, we do not want housing authorities and cascading down to 

residents who use the services of a self-sufficiency coordinators, we 

do not want folks to be harmed. And so for people who should not 

have been awarded money, we are going to make available extraordinary admin fees for them so they can continue, if they have already hired people and made employment commitments, that they 

will not be harmed and will be able to move forward and not have 

to take a loss and lay people off. 

Senator REED. Thank you, Madam Secretary. Just let me make 

two points, because my time is winding down. 

One, you in your proposal for essentially merging or consolidating both the FSS voucher program and the FSS program for 

public housing authorities, I think that is part of your design. That 

is reflective of legislation that I have submitted. 

Ms. HENRIQUEZ. Yes. 

Senator REED. And I think it makes sense. 

The second point—and you alluded to it, too—is this notion of 

banding together, spreading overhead costs, it is something I think 

we should all explore. You know, I am sure there are communities 

in South Dakota and New Jersey and Rhode Island where there is 

one housing official trying to cope with all of this in a really difficult climate, and so to the extent that we can incentivize this sort 

of coming together, maybe not formally but through sort of joint 

services or joint overhead, that would be very, very good. So any 

advice you have for us going forward, we would appreciate that. 

But thank you, Mr. Chairman, and thank you, Madam Secretary. 

Ms. HENRIQUEZ. Thank you, sir. 

Chairman JOHNSON. Senator Crapo. 

Senator CRAPO. Thank you very much, Mr. Chairman. First of 

all, I apologize. I am only going to be able to be here for just a couple of moments, but I did want to stop by and indicate to you, the 

Chair, as well as to our witness and to the other Members of the 

Committee that in these difficult budget times that we see and the 

understanding that I think we all have that funding issues are critical, I think it is important for us to focus on the kind of regulatory 

activity that the Department can bring and the focus it can bring 

to these housing issues. I think that the deregulation of Section 8 

is very critical and important and strengthening, and I would hope 

in that process that the Moving to Work Program could get a 

strengthening and a renewed strong focus as we move forward. 

But I just wanted to stop in and indicate my support for the 

process that is moving forward and encourage that we work closely 

together on it. 

170 

And, again, I apologize. I have been in four places this hour, and 

I have got another one to get to. So I apologize, and I am going 

to have to step right out. 

Chairman JOHNSON. Madam Secretary, do you have any comments about these issues? 

Ms. HENRIQUEZ. We just look forward to working with the Committee both in strengthening our regulatory oversight that is appropriate and balancing that with the needs of housing authorities 

to get their work done to serve the people who are housed in those 

programs. So thank you very much, sir. 

Chairman JOHNSON. Senator Menendez. 

Senator MENENDEZ. Thank you, Mr. Chairman, and thanks for 

calling this hearing. We had a hearing in the Subcommittee that 

laid a foundation, and I am pleased to see the Secretary here to 

build upon it. 

Madam Secretary, we have been discussing reforms to Section 8 

for some time now, and I think there is a tendency to forget how 

incredibly pressing the need for action really is. Affordable housing 

advocates and housing authorities back in New Jersey are telling 

me that these reforms cannot wait and that they are urgently 

needed now. So can you give the Committee a sense of the impact 

over time if Congress fails to act relatively soon, after such a long 

time of having this discussion, to implement specific reform provisions? What flows from that? 

Ms. HENRIQUEZ. That is a really good question. Thank you, Senator. 

I am taking a moment because I want to sort of get centered, because I think that there are lots of potential issues that will flow 

from this. 

As you know already, administrative fees, which is the money 

that housing authorities get for leasing units under the Section 8 

side, as those fees decrease, the workload does not. So what they 

have to do, the kinds of questions they have to ask, the kinds of 

documentation that is required on an annual basis does not decrease in spite of the fact that the funding to do that work has decreased, which has meant that housing authorities in some instances have had to lay people off. And that has led to longer waiting lists for people. Then people are on waiting lists longer, so they 

have lived in more difficult conditions longer. 

It has also meant that as you have laid off people with decreasing funding, that housing authority employees themselves will find 

themselves in difficult straits as well. 

The way in which we think about how that program gets managed gets more difficult. The less people but more workload or 

similar workload means potential for more error. Potential for more 

error means potential for wasted taxpayer dollars. And so we really 

do need to think about streamlining so that the work gets done, the 

people get house as quickly as possible, and the operations and the 

business processes for housing authorities are streamlined and efficient so that errors are minimized and maximizes the dollars, the 

precious resources we have. 

Senator MENENDEZ. I appreciate that. How about housing authorities refusing to run their voucher programs and turning down 

171 

VASH vouchers to assist homeless veterans and the loss of hard 

units? 

Ms. HENRIQUEZ. We have seen that in several instances, and, in 

fact, not just VASH vouchers, but we are seeing about a dozen 

housing authorities have decided that they are not going to operate 

a voucher program anymore, and they have made arrangements to 

convey that operation, to consolidate that operation with another 

larger housing authority. 

It means that the folks who need the subsidy, the affordability, 

are not getting served. It means that the amount of work that it 

takes to do the job well is not able to be supported. And it means 

most of all that we will have homeless veterans and other families, 

homeless families, in emergent conditions, and that should not be 

tolerated. 

Senator MENENDEZ. Let me just quickly—there are some core reform provisions that I would like to get your comment on. One is 

having a stable voucher renewal fund policy that would create predictability, because I am told it is very hard for housing authorities 

to plan for the year ahead when they do not know exactly what 

that will do; also to clarify how much money housing authorities 

can hold in reserves for a rainy day without those funds being 

taken back or offset; and also the flexibility provisions that are 

being—that have been discussed in project-based vouchers, enabling housing authorities to better assist families, especially elderly 

and disabled families, families transitioning out of homeless, to live 

in affordable housing communities of opportunity to receive services onsite. 

How would that predictability, clarity in the funding side, and 

the flexibility translate into more families served, if it does translate into that? 

Ms. HENRIQUEZ. Predictability is something that we would endorse wholeheartedly. It means that a housing authority can plan 

its business moving forward, it will understand its resources, and 

it can then tabulate its expenses and figure out how best to run 

its program. 

I would say that that does not just benefit the housing authority 

and its employees; it benefits the residents who are participating 

in those programs on the voucher side. We have heard in the past 

issues around shortfalls or money not being—not having sufficient 

funds to make sure that everybody who needs to be housed or be 

renewed, have their voucher renewed, will be able to do that. And 

this will make sure that we do not have to have those discussions 

again. So tenants will be protected, and participants would be protected in that regard. 

Further, I believe that a fixed formula funding, renewal funding, 

will mean that housing authorities are able to buildup small reserves. It right now is at about 3 weeks, and a 3-week reserve in 

a multi-billion-dollar program is really not a lot of money, particularly when you are running a voucher program which is tied to 

market real estate forces. And so while there are fair market rents 

and there are limits and so on, the natural tendency for a housing 

authority is to want to house as many people on its waiting lists 

as possible. That is why we are all in this business. Having that 

predictability will allow them to do that, particularly when it is 

172 

coupled with understanding what your reserve levels are and that 

will not be swept, and understanding that one of the things we 

keep asking for as well is the reallocation authority for the Secretary. So in some markets, it may be easier to lease, and you may 

have more room. And some housing authorities may not be able to 

lease as readily, and they will not use all of the money that has 

come to them. And so the ability to reallocate so we can continue 

to house and maximize housing across this Nation is something 

that we would look forward to as well. 

Senator MENENDEZ. Mr. Chairman, thank you very much, and 

thank you, Madam Secretary, for your answers. I look forward to 

working with the Chair and his leadership hopefully in the next 

Congress to see if this is something that we within the housing 

context could prioritize, because I think there are two shared goals 

here: getting more people to have a place to call home and, second, 

saving taxpayers’ money. So thank you very much. 

Ms. HENRIQUEZ. Thank you. 

Chairman JOHNSON. You support the idea of permitting PHAs to 

form consortia for purposes of forming partnerships to administer 

their public housing programs. Congress initially authorized the 

use of consortia in 1998, yet I understand barriers remain to PHAs’ 

taking full advantage of this authority. 

What is HUD doing to remove barriers to use of consortia and 

facilitate PHAs’ participation in consortia if they determine it will 

meet their local needs? 

Ms. HENRIQUEZ. There are several actions we are taking right 

now. First of all, consortia are allowed in voucher-administering 

agencies, but not on the public housing side, and so we are looking 

to extend the ability to have that happen in the public housing programs. 

In addition, right now under a consortia housing authorities, let 

us say three or four housing authorities band together to get some 

economies of scale, to simplify their operations, but they still have 

to fill out three or four separate reports to HUD because they are 

still seen as three or four separate public housing entities. And so 

we are looking at ways—again, this is why streamlining and administrative flexibility is so important, because we are trying to figure out ways in which housing authorities could file one report, for 

example, that would cover their agencies. We would still ask each 

housing authority to file for its own tenants and its own participants into what we call our PIC data base, which is our personal 

information and every single household in the voucher program on 

the public housing side. We would ask that under Family Self-Sufficiency there is one report that is done that covers what the goals 

are early on in the program and then if they have met those goals 

at a year-end report. And so we are looking at all sorts of ways— 

in fact, we have been working with a number of housing authorities, all range of sizes across the country, asking them what information do they need to run their day-to-day business about which 

they make their business decisions, and then translating that into 

what about that information we could collect and use—since they 

are doing it already, that we could then use to monitor them as 

well so that we are not asking for different information or in a different format than they already collect it. 

173 

Chairman JOHNSON. You mentioned your support for the Rental 

Assistance Demonstration enacted in fiscal year 2012—or RAD—in 

your remarks. Can you update us on the status of this demonstration? Second, can you also comment on a draft House proposal to 

authorize funds for use in this conversion demonstration and how 

these funds might be used to preserve assisted housing? 

Ms. HENRIQUEZ. Yes, thank you, sir. So the Rental Assistance 

Demonstration Program was authorized in fiscal year 2012. It is 

designed initially as a two-application period for public housing 

properties because we knew that there were housing authorities 

ready to submit and others who really wanted to spend some time 

thinking through their applications at a later date. 

The initial application period ended October 24th, just several 

weeks ago. We got a number of applications. That is still being tabulated in terms of how many, but they range from small housing 

authorities to medium to large housing authorities who have put 

proposals together, and we can provide greater tabulation once 

those initial awards are made. And on an ongoing rolling basis, applications are coming in after the October 24th date. We will look 

at those after this initial cut has been reviewed. 

As you know, the previous bill said that we could get up to 

60,000 units in at no cost, and either using project-based contracts 

or project-based vouchers. In addition, in that 60,000 cap is also 

authorizing for multifamily programs, rent supplement, RAP— 

rental assistance payments—and Section 8 mod rehab. 

So while we strongly support this program as a way to preserve 

public housing to get enough capital infused using private sector 

tools, financing tools, to get private money into the public arena to 

help rehabilitate and maintain these properties, we do know that 

there are a number of properties for whom this does not work because they have a larger capital need. And so we look forward to 

what we have seen in previous iterations on the House side, additional money going into that program which would help housing 

authorities with greater capital needs leverage greater amounts of 

private sector equity. 

But what we are seeing, which is really helpful, is housing authorities using a variety of tools for mixed finance deals to make 

this happen. Again, it puts them on the same real estate platform 

as everything else in the real estate marketplace, using the equity 

from properties to leverage capital improvement dollars, to make 

sure that properties are maintained at current standards and will 

continue to improve and continue to be available to serve the people who live there now and for future generations who need the 

economic stability. 

Chairman JOHNSON. I would like to thank you, Assistant Secretary Henriquez, for your testimony and for being here with us 

today. 

This hearing is adjourned. 

Ms. HENRIQUEZ. Thank you. 

[Whereupon, at 11:09 a.m., the hearing was adjourned.] 

[Prepared statements supplied for the record follow:] 

174 

1The average annual income of voucher program participants is approximately $12,500; for public housing families, the figure is slightly more than $13,500. 

PREPARED STATEMENT OF SANDRA B. HENRIQUEZ 

ASSISTANT SECRETARY FOR PUBLIC AND INDIAN HOUSING, DEPARTMENT OF HOUSING

AND URBAN DEVELOPMENT

DECEMBER 11, 2012 

Chairman Johnson, Ranking Member Shelby, and Members of the Committee, 

thank you for inviting me here today to testify regarding opportunities to reform 

the Housing Choice Voucher and public housing programs. 

As you know, the voucher and public housing programs provide critically important housing assistance in communities across the Nation. These programs serve extremely poor families, many of whom are elderly or disabled, or both. While the median income of American families today is just above $50,000, voucher and public 

housing families have substantially lower incomes. 1 Not surprisingly, with the recent recession, the demand for rental assistance has increased. 

At the same time, we have been tightening our belts at the Federal level, and 

HUD recognizes the urgent need to streamline and simplify its rental assistance 

programs in order to reduce the administrative burdens on PHAs and increase overall efficiency. In our FY12 and FY13 budget requests, we included measures that 

reduce administrative burdens and increase efficiency, as well as generate Federal 

cost savings. 

At the same time, and in light of the persistent need for deeply affordable rental 

housing, we are working hard to preserve public housing. For example, the Department’s Rental Assistance Demonstration (RAD) is providing participating PHAs 

with new options for addressing the capital needs of properties, enabling them to 

leverage private investment on terms and conditions similar to those available to 

private property owners participating in HUD’s multifamily programs. We expect 

that RAD will help to reverse the loss of public housing units and eventually place 

the inventory on a more sound, sensible regulatory footing for the long term. In the 

meantime, administrative streamlining is key to holding on to what we have. We 

also recognize that both preservation and administrative streamlining will be well 

served by continuing—and completing—HUD’s transition to a project-based framework for public housing. HUD recognizes both the necessity and the wisdom of moving in the direction of an oversight model for public housing that is more closely 

aligned with the multifamily project-based Section 8 portfolio and with traditional 

asset and portfolio management principles. 

Finally, the Department believes that PHAs should enjoy greater flexibility to respond to local housing needs, which in some cases means testing innovative strategies and engaging in partnerships tailored to local circumstances. The Department 

recognizes that greater flexibility must be coupled with measures to protect tenants, 

assure adequate HUD oversight, and evaluate results. 

Streamline and Simplify 

The Department is aware that there is broad external consensus among policy experts and practitioners for a number of key reforms that will streamline and simplify HUD’s rental assistance programs. In its FY13 budget request, HUD put forward a number of reforms around which there is such a consensus. These reforms 

include: 

1. Revising the threshold for medical deductions. The current threshold for the deduction of medical and related care expenses is 3 percent of family income. HUD 

proposes to increase the threshold to 10 percent of family income. This change 

would generate estimated savings of $150 million in the first year of enactment ($30 

million in the voucher program, $23 million in public housing, and $98 million in 

project-based Section 8). 

2. Consolidating the Family Self-Sufficiency program. Currently, there is a Family 

Self-Sufficiency (FSS) program for the voucher program and another for the public 

housing program. The programs are separate and administered independently. HUD 

proposes to consolidate the two programs and expand eligibility to project-based Section 8 owners, opening the program to multifamily tenants. 

3. Modifying the definition of extremely low-income. In areas where median incomes 

are extremely low (e.g., rural areas), working poor families may be skipped over for 

rental assistance, even if their incomes put them below the poverty level. This is 

the case for the voucher program, especially, because 75 percent of new admissions 

each year must have incomes at or below 30 percent of the area median. HUD proposes to define an extremely low-income (ELI) family as a family whose income does 

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not exceed the higher of the Federal poverty level or 30 percent of the area median 

income. This provision will generate estimated savings of $155 million (in the voucher program only) in the first year after enactment. 

4. Enacting a rent policy demonstration. Currently, HUD can test and evaluate different rent-setting policies only at Moving to Work (MTW) agencies, since other 

agencies are not authorized to alter their rents beyond what is permitted in statute. 

HUD proposes to carry out a rent policy demonstration at any agency ‘‘for the purpose of determining the effectiveness of different rent policies in encouraging families to obtain employment, increase their incomes, and achieve economic self-sufficiency, while reducing administrative burdens and maintaining housing stability.’’ 

5. Establishing a flat rent floor. PHAs are required to establish a flat rent ‘‘based 

on the rental value of the unit’’ and to offer public housing families the option of 

paying the flat rent or an income-based rent. In order to align public housing flat 

rents more closely with market rents, HUD proposes to establish a flat rent floor 

set at 80 percent of the applicable FMR. To assure that no family’s rent would increase by more than 35 percent in any one year, the increase would be phased in 

where applicable. Once fully implemented, this provision would reduce costs by approximately $400 million. 

6. Changing the definition of a PHA to include a consortia of PHAs. Currently, there 

is statutory authority for PHAs to form consortia for the purposes of administering 

the voucher program, but not for administering public housing. HUD proposes to 

amend the definition of a ‘‘public housing PHA’’ to include a ‘‘consortium of PHAs’’ 

so that PHAs will be able to reduce their administrative costs and achieve operating 

efficiencies by combining their operations, should they choose to do so. 

7. Authorizing biennial inspections for HCV units. Currently, HCV units must be inspected on an annual basis, regardless of whether such units have a record of regular compliance with HUD’s physical condition standards. To reduce the administrative and financial burden on PHAs and high-performing landlords, HUD proposes 

to authorize biennial inspections, enabling PHAs to concentrate their inspection resources on the more marginal and higher-risk units. Importantly, residents would 

retain their right to request an inspection. 

While each of the above-described provisions requires statutory authority, we 

have established a cross-program working group to identify streamlining and simplification measures that HUD can implement through regulation or notice and are 

moving aggressively to implement these measures. In addition, we are exploring further streamlining measures that require statutory authority and may be worth pursuing in FY14. 

A Stronger Foundation for Public Housing 

Our commitment to streamlining and simplification extends beyond the provisions 

identified above. As we look a bit further out on the horizon and consider the future 

of public housing, in particular, we recognize the importance of aligning our oversight structure with basic asset management principles. 

Small PHAs, in particular, view our existing oversight structure—known as the 

‘‘Public Housing Assessment System,’’ or PHAS—as increasingly unworkable. They 

assert that PHAS is heavy-handed, that small PHAs pose little risk to HUD, and 

that HUD should therefore scale back its oversight of small PHAs. I understand and 

appreciate these concerns. We have taken some steps to adjust how PHAs are scored 

under PHAS, and we are willing to consider others. We are interested, however, in 

pursuing broader reform in this area in the interest of protecting tenants and the 

taxpayer’s substantial investment in public housing. Reform that embraces traditional asset management principles and practices will also bring substantial administrative relief to PHAs of all sizes, helping to put the public housing portfolio on 

a more solid foundation. 

Reform of HUD’s oversight structure is the next step along a path whose initial 

direction was established during the prior Administration, with the implementation 

of ‘‘asset management.’’ Asset management entailed movement from a system where 

accounting, budgeting, funding, and management were all performed at the agency 

level to a system where these functions are now performed at the project level. 

Movement along this path picked up a strong head of steam with enactment of 

the Rental Assistance Demonstration (RAD), which is a top priority of the Department. RAD addresses the contractual relationship between PHAs and HUD. By offering PHAs the option to convert to a long-term, project-based Section 8 contract, 

RAD facilitates lending to and investment in individual public housing properties. 

Without a doubt, asset management laid the groundwork for RAD by beginning to 

build an operating history at the individual project level. This information is critiVerDate Nov 24 2008 09:17 Apr 26, 2013 Jkt 048080 PO 00000 Frm 00179 Fmt 6621 Sfmt 6621 L:\HEARINGS 2012\08-01 & 12-11 HUD S RENTAL HOUSING ASSISTANCE PROGRAMS, 
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2There are currently 35 MTW agencies. 

cally important to the lenders and investors who will be underwriting public housing preservation transactions under RAD. 

Moving HUD’s oversight of public housing to a true asset management model is 

the next step on the path toward putting the public housing portfolio on a stronger 

foundation and reversing the portfolio’s isolation from the affordable housing mainstream. As we move ahead, we look forward to working with the Committee and 

our industry partners as we pursue this important change. 

Moving to Work 

The Moving to Work (MTW) program was authorized in 1996 as a demonstration 

program. The purpose of the program is to provide a limited number of PHAs 2 with 

the statutory and regulatory flexibility to test approaches to providing housing assistance that reduce costs and increase cost-effectiveness, reward work and employment, and increase housing choices for low-income families. 

Since its enactment, MTW has enabled PHAs to pioneer innovative practices 

around approaches to serving homeless families, building resident earnings and assets, leveraging private capital through the project-basing of vouchers and other 

strategies, and achieving operating cost efficiencies through streamlined approaches 

to income recertifications, inspections, and the calculation of utility allowances. For 

example: 

• Home Forward (Portland, Oregon) made an award of project-based vouchers to 

a local not-for-profit organization that provides housing to formerly homeless 

veterans. The building is served by a full-time resident services coordinator, and 

supportive services are provided by the Veteran’s Health Administration. Home 

Forward also uses its single-fund flexibility to provide security deposits to veterans using Veterans Affairs Supportive Housing vouchers to lease rental units. 

• The King County Housing Authority (KCHA) is able to leverage its MTW flexibilities to build programs involving local partners that bring their own sources 

of funding to the table. For example, KCHA developed a Resident Opportunity 

Plan (ROP) in partnership with the local YWCA; Bellevue College, Hopelink; 

and Washington State’s Department of Employment Security. Through the 

ROP, participating residents receive wrap-around services and financial assistance so they can acquire the skills needed to increase their earned income and 

ultimately graduate from federally assisted housing. KCHA’s flexibility under 

MTW provides it with the latitude to refine the program iteratively and incrementally, improving resident outcomes as the program progresses, while also 

supplementing the sources of funding brought by other partners, which are typically constrained to particular activities. 

• The Cambridge Housing Authority implemented a tiered rent structure that 

combines elements of an income-based rent and a flat rent. Rents are established for various income bands and set at 30 percent of adjusted income at the 

low end of each band. This approach, which is combined with a hardship exemption, produces much-needed rent simplification for both the PHA and residents. 

As you know, the Department supports the principles of MTW, including appropriate recordkeeping, reporting requirements, and rigorous evaluation. We look forward to working with the Committee as it considers potential reforms and improvements to the MTW program. 

Conclusion 

Mr. Chairman, there is an unquestioned need for rental assistance in communities across the Nation. At the same time, there is longstanding consensus around 

a set of reforms that will streamline and simplify administration of the Housing 

Choice Voucher and public housing programs. HUD is committed to improving not 

only the administration of these programs, but its oversight of the public housing 

program, in particular. Finally, the Department recognizes that greater flexibility 

for PHAs must be coupled with measures to protect tenants, assure adequate HUD 

oversight, and evaluate results. Thank you for your consideration of these comments, and I look forward to addressing your questions.