After NAHRO’s Urging, HUD Expands Administrative Fee Eligible Uses

On June 13th, HUD published a notice [Notice PIH 2022-18 (HA)] expanding the eligible uses of the administrative fee for the Housing Choice Voucher (HCV) program. The notice is titled “Use of Housing Choice Voucher (HCV) and Mainstream Voucher Administrative Fees for Other Expenses to Assist Families and Lease Units.” Earlier this year, NAHRO had written to HUD recommending that it expand the eligible uses of the HCV administrative fee in order to increase voucher utilization. NAHRO wrote that HUD should “[i]mmediately issue guidance in the form of a new PIH notice clarifying that administrative fees may be used for activities and expenses that help a PHA utilize vouchers . . . .” NAHRO is pleased that HUD recognized–after NAHRO’s urging–the importance of allowing administrative fees to be used for these additional purposes, which will have the end effect of helping more families find and lease homes.

The notice clarifies that administrative fees may be used for the following activities:

• Administrative Activities: These activities include–but are not limited to the following:
  • Front-line, day-to-day operational activities:
    • applicant intake;
    • lease-up activities;
    • income determinations and reexaminations;
    • unit inspections;
    • disbursing HAP to landlords;
    • policy and operational planning and implementation;
    • financial management;
    • HCV record-keeping and reporting;
  • Indirect overhead activities associated with operating the HCV program:
    • PHA management;
    • human resources;
    • legal;
    • finance;
    • accounting and payroll;
    • information technology;
    • procurement;
    • quality control;
    • central office cost center HCV program expenses;
  • Housing search assistance activities;
    • pre-move counseling;
    • helping a family identify and visit potentially available units during their housing search;
    • helping a family find a unit that meets the household’s disability-related needs;
    • providing transportation and directions; and
    • assisting with the completion of rental applications;
  • Post-lease up activities related to search assistance:
    • post-move counseling and landlord/tenant mediation;
  • HCV owner recruitment and outreach activities:
    • costs associated with materials or webpages specifically geared to owners;
    • costs of landlord liaison staff;
    • associated expenses;
• Other Eligible Activities (PHAs must change their administrative plans to support these activities; Note: some of these activities have certain restrictions, please see Notice PIH 2022-18 (HA) for specifics on use):
  • Expenses for activities designed to help assist HCV families in leasing units:
    • Owner incentive and/or retention payments;
    • security deposit assistance;
    • utility deposit assistance/utility arrears;
    • application fees/non-refundable administrative or processing fees/refundable application deposit assistance/broker fees;
    • holding fees; and
    • renter’s insurance if required by the lease.

Additionally, administrative fee reserves or outside funding sources may also be used for the listed activities. Similarly, mainstream voucher administrative fees may also be used to assist mainstream voucher families to lease units, though mainstream administrative fees may only be used for mainstream vouchers. The notice also notes that for both regular and mainstream HAP funding may not be used to pay for any of these activities. Finally, the notice provides certain information on reporting the new authorized expenses.

The full notice may be found here.