NAHRO Sends Letters to HUD on HOTMA and Triennial Certifications

In order to maintain the spotlight on issues important to our members, NAHRO sent two letters to HUD last week.

The first letter (member login required) was on the Housing Opportunity Through Modernization Act of 2016 (HOTMA) and focused on the Project-Based Voucher (PBV) provisions that HUD is currently implementing through Federal Register notice. In addition to other provisions, this notice included two provisions very important to our members. The first allows PHAs to choose to calculate their general project-based cap based on either voucher funding or voucher allocation. The second allows PHAs to project-base up to 30 percent of their vouchers in units targeted to the homeless, veterans, elderly, people with disabilities or in areas where vouchers are difficult to use. HUD has been discussing reopening this Federal Register notice for additional public comment. NAHRO’s letter explained the importance of these provisions to PHA operational flexibility and local housing need, while noting that if the public comment period is reopened, the effective date in the original notice of April 18, 2017 should remain.

The second letter (member login required) was on the triennial recertification interim final rule required by the Fixing America’s Surface Transportation (FAST) Act. Language permitting triennial recertifications was a hard-earned and significant win for PHAs across that country that are currently facing historically low levels of federal funding. On January 19, 2017, HUD previewed an interim final rule that would implement the triennial recertification provision of the FAST Act, but it was never actually published in the Federal Register due to the regulatory freeze on the new administration, so the FAST Act triennial recertification provisions were not implemented. NAHRO’s letter asked for the FAST Act triennial recertification interim final rule to be published, since the 60-day regulatory freeze period is now over.