MHDA Spring Conference 2013 Chandra Broadnax, Program Analyst Detroit Field Office PIH

PHA Plan Process

 Established by Section 5A of the United States Housing Act of 1937 (42 U.S.C. 1437 et seq.). Section 5A(b) of the U.S. Housing Act of 1937 (42 U.S.C. 1437c 1(b))  Amended by the 2008 Housing and Economic Recovery Act (HERA), Sections 2701 and 2702, Small Public Housing Authorities Paperwork Reduction Act.

Related information

 PIH Notice 2008-41  Provides guidance for the process of PHA Plans  Implements Title VII ○ Qualified vs Non-Qualified PHAs  Implements revised PHA Plan templates  Implements revised Certifications

HERA  Signed July 30, 2008  Provided exemptions for Qualified PHAs  Provided revised FO review protocol for Qualified PHAs 

The Detroit Field Office is not required to review annual plans submitted by Qualified PHAs

Two Categories of Distinction

 Less than 550 Units  Not Designated troubled under PHAS  No failing SEMAP during the prior 12 months

Non-Qualified PHAs Any PHA that doesn’t meet those thresholds Qualified PHAs

How Do I know if I am Qualified?

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HUD posts the Qualified PHA list on HUD.GOV

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If you have any questions contact your PHRS

Am I still Qualified?

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What if my status changes after the "Qualified" PHA list is posted on the PHA Plan webpage?

 Your PHA will continue to be monitored pursuant to the posted rating until a new list is published

Why a PHA Plan?

Needs Budget Strategic Planning Programs & Policies Tenants, Community and Quality of Life Goals

Basic Components of a PHA Plan

1.

Five Year Plan

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Every Fifth Year regardless of designation

2.

Annual Plan

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Every Year if unqualified or troubled

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Certifications are still required annually

Five Year Plan

 First submission required in 2000  Guidance and Regulation  PIH 2000-43 , III.B.8

 24 CFR 903.19  24 CFR 903.6

Changes or Amendments to the Five Year Plan  Per 24 CFR 903.21

 You may amend or modify the Five Year Plan  If the change is outside of the previously submitted/approved substantial deviation, you must comply with initial submission requirements of the plan (including timelines) i.e.

○ RAB, Consistency with the Consolidated Plan, 45-Day Public Review, Board Resolution, Official submission and review by HUD

Substantial Deviation/Significant Amendment



Substantial Deviation

 At your discretion  You must state basic criteria in the annual plan  Definition must be included in Section 10 ○ Or provided as an attachment 

PIH-99-51

 Changes to rent or admissions policies or organization of the waiting list;  Additions of non emergency work items not previously included  Change in use of replacement reserve funds under CFP  Any change in demo/dispo  Any change in homeownership  Any change in conversion

What if there are changes to the approved 5 YR Plan?

 On an as-needed basis, you can submit a revised plan ○ Changes are outside of the significant deviation or significant amendment/modifications to the approved CFP Five-Year Action Plan.

○ The actual difference in costs, work items, etc. would need to be determined in the deviation

Discussion on Field Office Review Process

What to Submit and Where to Submit it

Form/Certification HUD 50077 HUD 50070 HUD 50075 HUD 50075.1

HUD 50075.2

HUD 50077-CR HUD 50071 Form SF-LLL HUD 50077-SL Submission Method to HUD

Email/Mail Email/Mail PHA Plan Website PHA Plan Website PHA Plan Website Email/Mail Email/Mail Email/Mail Email/Mail

Submission Due Dates

FYE (Fiscal Year Ending)

12/31 3/31 6/30 9/30

FYB (Fiscal Year Beginning)

Jan 1, 2013 April 1, 2013 July 1, 2013 Oct 1, 2013

Due Date

Oct 18, 2012 Jan 16, 2013 April 17, 2013 July 18, 2013

PHA Plan Review

If approved, PHA Plan Coordinator posts to PHA Plans Website PHA Submits initial or subsequent version of PHA Plan to PHA Plan Website Director Signs letter and PHA is notified of approval or identified deficiencies Entire Process should take 75- Days or less FA Review PHA Plan Coordinator pulls plan/tracks submission date PHA Plan Coordinator Alerts the PMT Team & Review begins PHRS conducts the Field Office Review Process FM Review Any questions regarding PHA Plans can be directed to your assigned PHRS

Question and Answer

Five Year Plan/Annual Plan and GPNA  Question- When is my GPNA submittal due? Do I have to complete the GPNA before I do my next PHA Plan?

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Answer – Depends…

 Question- Do I have to do a GPNA even if I do not have enough money to make all of the improvements?

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Answer – Yes, it is the basis as contained in the PHA Plan

Five Year Plan/Annual Plan and GPNA

 Question- Am I required to include each and every ECM in my Capital Fund 5-year and annual plans?



Answer – No, only those energy conservation measures (ECMs) for which you have funds

Q & A / Resources

Brief HUD Updates

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PIH Notice 2013-10 Emergency Safety& Security Funding (5/3/2013)

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Applications due by June 19 th , 2013

○ This year, Congress appropriated $20 million in funding to provide assistance to “public housing agencies for emergency capital needs including safety and security measures necessary to address crime and drug-related activity as well as needs resulting from unforeseen or unpreventable emergencies and natural disasters excluding Presidentially declared disasters occurring in fiscal year [2013]

PIH 2013-07 (3/5/2013)

 Agreements with Responsible Entities and Timing for Environmental Reviews

Brief HUD Updates

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PIH 2013-06 (2/4/2013)

 Radon Information For PIH Programs 

PIH 2013-04 (1/28/2013)

 Guidance on Verification of Excluded Income 

PIH 2013-03 (1/22/2013)

 Public Housing and Housing Choice Voucher Programs – Temporary Compliance Assistance  (FAQ posted on 3/1/2013)

HUD.GOV Resources

 PHA Plan/Five Year Plan/Annual Plan http://portal.hud.gov/hudportal/HUD?src=/program_offices/public_indian_housing/p ha  EPIC & Five Year Plan/Annual Plan http://portal.hud.gov/hudportal/HUD?src=/program_offices/public_indian_housing/pr ograms/ph/capfund/epic  PNA/GPNA http://portal.hud.gov/hudportal/HUD?src=/program_offices/public_indian_housing/progra ms/ph/capfund/physicalassessment  GPNA Tool http://portal.hud.gov/hudportal/HUD?src=/program_offices/public_indian_housing/progra ms/ph/capfund/gpnatool  Notices, Rules, & Regulation http://portal.hud.gov/hudportal/HUD?src=/program_offices/public_indian_housing/publicat ions/notices  PIH News to Use – http://portal.hud.gov/hudportal/HUD?src=/program_offices/public_indian_housing/post/an nounce