Key Points from Updated PIH FAQ

Here are some key points from HUD PIH’s updated FAQ. This blog post only highlights certain key points in the FAQ; the complete FAQ should be read.

• Questions can be sent to PIH-COVID@hud.gov;
• Coronavirus eligible activities –
  • Eligible uses of Operating and Capital Funds (until Dec. 31, 2020):
    • Staff labor hours for emergency planning and response;
    • Personal protective equipment (PPE);
    • Cleaning supplies such as disinfectants and sanitizers;
    • Contracted services for cleaning;
    • Transportation of staff to perform essential functions and assist residents;
    • Capital expenditures designed to improve the safety of residents such as improved ventilation systems and high-grade filters, portable air filtration equipment, and portable humidifiers;
    • Necessary equipment to protect people engaged in modernization activities;
    • Public health training;
    • IT equipment and upgrades; and
    • Sanitation equipment for common areas;
  • Eligible uses for administrative fees and administrative fee reserves:
    • HCV and PBV staff labor hours for planning and response;
    • Personal protective equipment (PPE);
    • Cleaning supplies for the office such as disinfectants, sanitizers, etc.;
    • Costs to transport staff to perform essential functions;
    • Costs to upgrade equipment or technology to facilitate electronic communication and reduce reliance on in-person meetings and transactions;
• Eviction moratorium –
  • New COVID-19 legislation includes a 120 day moratorium on evictions for nonpayment of rent (including fees and penalties);
  • HUD will issue additional guidance;
• Inspections –
  • REAC is postponing property inspections for PIH and Multifamily properties, unless there is an exigent circumstance or reasonable belief of a threat to life or property;
  • HQS –
    • HUD is considering alternative guidance or waivers based on flexibilities in recent COVID-19 legislation;
    • Currently, PHAs may utilize the following flexibilities:
      • Move to biennial inspections (PIH 2016-05);
      • Move to triennial inspections if a small, rural PHA (Notice FR-6115-N-02);
      • Accept alternative inspections for periodic inspections (PIH 2016-05) and accept alternative methods for validating the correction of a deficiency (e.g., photo or owner certification);
      • Allow families to move into units that fail HQS, if failure was non-life threatening (PIH 2017-20);
      • Adopt Housing Opportunity Through Modernization Act of 2016 (HOTMA) Alternative Inspection provision allowing families to move in before an HQS provision as been completed, if the unit has passed an acceptable alternative inspection;
• Amending Admin. plan requirements
  • HUD is considering waiving the requirements to amend a PHA’s Admin plan;
• Portability –
  • PHAs should continue to process incoming and outgoing ports similarly to how they are processing other operational issues;
  • HUD is not considering a portability waiver;
• Waiver Requests –
  • PHAs should not submit waiver requests until new guidance is issued;
• Stimulus Payments –
  • Stimulus payments directly to individuals and families are to be excluded from income “as they are temporary, non-recurring payments”;
• Required public meetings must still be held, but if there’s an active emergency may be held remotely or online provided PHAs can accept questions and post answers;
• Shelter-in-place orders –
  • PHAs should use alternate methods to collect information for new admissions and interim reexaminations for reduced wages or hardship exemptions. Alternate methods include email, mail, and phone.