New RAD Notice, Revision 4 Released

Earlier today, HUD released the new Rental Assistance Demonstration (RAD) notice: “Rental Assistance Demonstration – Final Implementation, Revision 4” (Notice H-2019-09; PIH-2019-23 (HA)). The RAD program allows for units to be converted from certain Department of Housing and Urban Development (HUD) funding streams, such as public housing, to either a Section 8 project-based voucher (PBV) funding stream or a Section 8 project-based rental assistance (PBRA) funding stream. There are several major changes in this notice, including changes to the First Component of RAD (which allows public housing units to be converted to PBV or PBRA) and implementation of the 2018 Appropriations Act provision allowing Section 202 project rental assistance contracts (PRAC) to be converted to PBV or PBRA.

The changes to the First Component of RAD include the following:

• A policy that RAD rents will be updated every two years (RAD awards after each update will use the updated rents);
• A newly added “Concept Call” step to the RAD process, to allow PHAs to receive confirmation that project plans are sufficiently advanced to submit a Financing Plan;
• More stringent notice requirements for residents in developments to be converted (the new notice details resident participation requirements at each step of the RAD process);
• A policy that all households residing in regular PBV units will have the same resident rights extended to them as households that reside in RAD-PBVs in converted developments;
• A mechanism for PHAs to enter into partnerships with each other to convert developments;
• A policy allowing for rent increases in certain scenarios for PBRA conversions, such as developments located in Opportunity Zones;
• Elimination of the requirement to submit the Capital Needs Assessment (CNA) tool in certain scenarios; and
• Other changes (including changed requirements for portfolio awards, a change in how PHAs report debts owed, and broadening the use of “tiered environmental reviews”).

At this time, NAHRO staff are still reviewing the new notice. Additional analysis will be provided in future NAHRO publications.

The RAD Notice, Revision 4 can be found here.

[2:17 pm edit – The new notice can also be found on HUD’s RAD website here.]