Northwest Notes

Office of Public Housing

Region X - Alaska, Idaho, Oregon, Washington
FY2008 Quarters I & II - February 8, 2008

The Director's Corner
Welcome to a new year doing what you do best - helping to address the most challenging housing needs in our communities.

HUD's Asset Management Initiative will continue to evolve in the near future, presenting many new opportunities along the way. We look forward to meeting these challenges with you.

On behalf of Office of Public Housing team members in the Seattle, Portland, & Anchorage offices, we hope this newsletter is helpful to you.

Harlan Stewart, Director, Office of Public Housing, Region X

Family Self Sufficiency Annual Meeting For Coordinators

Rosanne Chavez, Seattle Office of Public Housing, leads a discussion on FSS topics.

The Public Housing Offices of Seattle and Portland held their annual Family Self-Sufficiency (FSS) Conference on September 21, 2007 in Vancouver, Washington. A BIG thank you goes to the Housing Authority of the City of Vancouver for its generosity in providing meeting space.

There were over 50 attendees, representing 23 housing authorities from Oregon, Idaho, and Washington. Presenters included Rebecca Tuttle, Rosanne Chavez and Suzanne Manville from HUD's Office of Public Housing in Seattle; and Chad Trepinski from the Portland HUD Office.

Conference calls were held with Kathryn Greenspan, Housing Programs Specialist from the Housing Voucher Management and Operations Division in HUD Headquarters; as well as Judith Chavis of the American Association of Service Coordinators.

The format was based on open discussions with all participants on the FSS Annual Report and Logic Models, FSS participant transfers between subsidized programs, Program Coordinating Committees, Best Practices, Individual Training & Service Plans (ITSPs) and Case Management, FSS data in PIC, and maintaining ongoing interest and involvement by the FSS family. Great ideas were presented and shared by all participants, resulting in a very successful conference.

Watch for information on the 2008 FSS Meeting!

Need More Capital? CFFP Could be the Key
HUD's Capital Fund Financing Program (CFFP) allows a PHA to leverage capital funding to accomplish work items exceeding the current amount of capital funding on hand. Under an approved CFFP plan, a PHA may borrow private capital (bond or conventional loan) to make improvements to public housing now, pledging a portion of future years' capital funds to the debt service!

General guidelines include:

• Approval - PHAs must submit an application to HUD for prior approval.
• CF Pledges - Generally limited to 33% of the PHA's current annual CF grant.
• Term - Generally, 20 years.
• Public Housing Requirements - Since the proceeds from a CFFP transaction are generated via the pledge and use of Capital Funds, HUD considers CFFP Proceeds to be, for all intents and purposes, Capital Funds. PHAs pursuing a CFFP transaction must follow all statutory and regulatory requirements related to the Capital Fund Program in regard to the development and implementation of their CFFP Proposal.
• Other Financing/Approvals - If a PHA's proposed use of the proceeds would require other HUD approvals, separate approvals must be obtained. CFFP Proposal approval can occur prior to those related approvals, but will be conditioned upon receiving those approvals, and generally will expire within 90 days of issuance.

More information, including application procedures and case studies of approved CFFP proposals can be found on our website.

Webcasts
View our Webcast archive

• PIH EIV Training, 1/16/08
• PH Neighborhood Networks NOFA, 1/15/08
• Disaster Housing Assistance, 1/10/08
• Subsidy & Grants Information
• System (SAGIS) Operating Fund Project Level Submissions, 12/12/07
• Environmental Assessment Training, 11/27-28
• Disaster Housing Assistance, 11/8/07
• REAC: Housing Choice Vouchers, 11/6/07
• Disaster Housing Assistance, 10/18/07

Housing Choice Voucher (HCV) Homeownership
HCV Homeownership Closings as of 12/31/2007

HUD Highlights Regional Office Newsletter
Find out what's new in the Region across all HUD program areas. Sign up to receive this electronic newsletter.

HUDCLIPS has Moved to www.hud.gov
HUDCLIPS has long been due for a makeover... and just in time for the New Year, that makeover has happened! The redesign of HUDCLIPS, HUD's forms and handbooks website, is finished.

Content from the old HUDCLIPS site moved to the Department's official Web site at www.hud.gov on January 1, 2008. The redesign makes it much easier to find HUD forms, handbooks, and notices.

To access the new and improved HUDCLIPS, go to www.hud.gov and choose the Handbooks/forms link under "Resources" in the left menu column. Bookmark HUDCLIPS for even quicker access!

PIH Information and Resource Center
The answer is just a phone call away...
Here are just a few of the reference and referral services that the PIH Information and Resource Center provides to the General Public, Public Housing and Section 8 Residents, and Housing Agency Staff:

• Local Agency Contact Information
• PH Guidebooks and Notices
• Public Housing, Section 8, Homeownership fact sheet and more
• Applicable References to CFRs

Can we help you?
Contact us Monday - Friday, 9am - 5pm EST
Phone: (800) 955-2232 Fax: (817) 922-8885
Email: PIHIRC@nelrod.com

Did you Know? - E-Data Storage
Many PHAs have inquired whether documents may be scanned into an electronic filing system in lieu of warehousing paper documents. After consultation with the program office at Headquarters and the Office of General Counsel, HUD has concluded that electronic filing systems are permitted under current regulations.

HUD's main concerns are with auditability. One concern raised by the Office of Inspector General is the use of original signatures in prosecuting criminal cases. Only tested cases will provide an answer to that. As for program requirements, the following analysis is offered:

The ACC for the Rental Certificate and Rental Vouchers Program contains record keeping requirements (Section 14 of the Form HUD-52520). The relevant section reads: "The [Housing Authority] must maintain complete and accurate books of account and records for a program. The books and records must be in accordance with HUD requirements, and must permit a speedy and effective audit." The ACC for the administration of public housing contains identical language (Section 15 of Form HUD-53012A). Neither version of the ACC defines "records" or provides specific guidance.

HUD regulations provide limited guidance to PHAs with regards to electronic recordkeeping. Specifically, HUD regulations require that PHAs operating public housing or section 8 to electronically submit certain family data to HUD for those programs. See 24 C.F.R. § 908.101. In addition (and in keeping with the requirement for electronic transmission to HUD), with respect to the Housing Choice Voucher program (HCV), the record keeping requirement states, among other things, that "the records must be in the form required by HUD, including requirements governing computerized or electronic forms of record keeping." 24 C.F.R. 982.158(a). Other than the regulations mentioned above, there does not appear to be a specific requirement under the HCV program that records be maintained in a particular form (paper versus electronic).

More broadly, 24 C.F.R. 85.42 also discusses record keeping requirements, such as what records are applicable, the starting date of the records retention and length of the retention period. This record keeping regulation applies to all financial and programmatic records, supporting documents, statistical records, and other records of grantees or sub-grantees, which are:

• Required to be maintained by the terms of this part, program regulations or the grant agreement, or
• (ii) Otherwise reasonably considered as pertaining to the program regulation or the grant agreement. 24 C.F.R. 85.42(a)(1)

Further, the regulations provide that "[c]opies made by microfilming, photocopying or similar methods may be substituted for the original records." 24 C.F.R. 85.42(d).

In conclusion, based upon a review of the ACCs and HUD regulations, we are of the opinion that neither the ACC nor HUD regulations preclude housing authorities from maintaining their records in electronic form. Electronic documentation is the wave of the future, and for several housing authorities, that wave is already here!

Did you Know? - Audit Requirements Summary
Low Rent & Section 8 Audit Requirements

• Non-Federal entities that expend $500,000 or more in a year in total Federal awards shall have a single or program-specific audit conducted for that year (per OMB Circular No. A-133). A program-specific audit is allowed when an auditee expends over $500,000 under only one Federal program.
• Non-Federal entities that expend less than $500,000 a year in total Federal awards are exempt from Federal audit requirements for that year.
• PHAs whose ACC is executed by a City/Town expending less than $500,000 in total Federal awards are required to submit electronic and hard copy reports if the total Federal awards expended by the City or Town exceeds $500,000. In these cases the City/Town is required to obtain a single audit which includes both entity's financial statements and the Federal awards.

• 1998 Rule codified @ 24 CFR Section 5.801
• Require PHAs that administer HUD Programs to submit an un-audited Financial Data Schedule (FDS) to HUD/REAC electronically no later than 2 months after the FYE.
• PHAs that are required to submit audited financial data (total Federal expenditures over $500,000 during FYE), or elect to have an audit performed, must also electronically submit an audited FDS (to REAC) and send a hard copy of the audit report to the Field Office no later than 9 months after the FYE.
• Electronically submit via the REAC Financial Assessment Subsystem (FASS).
• PHA & Auditor User Guide
• Under Helpful Tools-see electronic submission tips
• REAC Hotline - (888) 245-4860

• Electronic un-audited (FDS) submissions are due no later than 2 months after the FYE.
• Electronic audited (FDS) submissions are due no later than 9 months after the FYE.
• Hard copy audit reports, as well as audit management letters, and any corrective action plans, are due no later than 9 months after the FYE.

• Section 8 PHA's with FYE 12/31/05 and later that fail to electronically submit un-audited, and if required, an audited financial data schedule (FDS) within the established timeframes, will be sanctioned a 10% penalty against monthly admin fees until submitted. This is a permanent reduction for the current calendar year.

• PIH Notice 2005-11
• PIH Notice 2006-03
• PIH Notice 2006-15
• PIH Notice 2007-08
• PIH Notice 2007-14

Capital Funding - Environmental Reviews
Capital Funding is subject to Environmental Review under 24 CFR Part 50 or Part 58. CFP Funds established in LOCCS are placed under threshold review, limiting PHA access to the full amount pending satisfactory completion of the Environmental Review.

REAC Readiness - Compilation Bulletins
REAC Compilation Bulletins provide updated inspection protocols and procedures, including information on scheduling and postponing inspections. Compilation bulletins instruct REAC inspectors how to handle fire extinguishers, window safety bars and other items which may affect your site and overall PASS score. The bulletin has just been updated and is available to PHAs online for ready reference. Be ready for REAC by having the latest information! View, print or download the REAC Compilation Bulletin, Revision 1, dated January 1, 2008

Uniform Physical Condition Standards (UPCS)
REAC inspections are performed in accordance with the UPCS. If a PHA diligently inspects and maintains property applying the same standards as REAC, the PHA will know what deficiencies a REAC inspector is likely to identify and can repair those items prior to the inspection. For UPCS Training information, contact REAC's Technical Assistance Center at (888) 245-4860 (7:00am - 8:30pm ET) or email the Inspection Training Team directly at REAC_PASS_Training@hud.gov

Go Green to $ave Green!
Energy Performance Contracting
Energy Performance Contracting (EPC) is an innovative financing technique that uses cost savings from reduced energy consumption to repay the cost of installing energy conservation measures. Normally offered by Energy Service Companies (ESCOs), this innovative financing technique allows users to achieve energy savings without up front capital expenses. The costs of the energy improvements are borne by the performance contractor and paid back out of the energy savings. Other advantages include the ability to use a single contractor to do necessary energy audits and retrofitting to guarantee the energy savings from a selected series of conservation measures.

Learn more today at this helpful website, which includes case studies, success stories, training materials and contacts!

For timely tips on reducing seasonal energy costs and a directory of energy saving ideas, visit energystar.gov

Check the PHECC
As energy costs rise, superior energy management is just good business. Need tips on evaluating your PHA's energy performance? Creating a comprehensive energy action plan? Need energy savings informational materials for residents? HUD's Public Housing Energy Conservation Clearinghouse (PHECC) offers a cost reduction toolbox, educational materials for residents in English and Spanish, and the latest available information on upcoming training sessions around the country.

Recently Published Guidance
For a complete list of Federal Register and Notices published, please visit the new HUDCLIPS website.

E-Memos (electronic memoranda) published through December 10, 2007

Important Upcoming Dates

Please Note: All dates subject to change. Refer to program area websites for most current information and complete list of forms due!!!

Ensure data is submitted timely and accurately.
Failure to report timely could result in loss of Administrative fees. Check VMS website for exact submission dates http://www.hud.gov/offices/pih/centers/fmc/

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