Affordable Housing News

Vol. 22 Issue 13

Service Coordinator eLOCCS Form Revisions Posted for Public Comment(Colleen Bloom, LeadingAge) - On April 28, the U.S. Department of Housing and Urban Development (HUD) issued a 60-day notice soliciting comments on modifications to one of the forms used in the Service Coordinator in Multifamily Housing grant program.

In particular, this notice seeks public comment on a revised LOCCS Payment Voucher form HUD-50080-SCMF.

Subsequent to the publication, HUD service coordinator program staff also issued a series of clarifications in response to certain questions received.

We have included them here (see numbered list at the end of this article).

AASC Analysis of Implications

According to the American Association of Service Coordinators, this notice is particularly important to staff responsible for administration of service coordinator grants.

Grantees of the Service Coordinator in Multifamily Housing for the Elderly/Disabled program will submit the revised form HUD-50080-SCMF on a semi-annual basis, based on the individual grant period.

For example, if the grant period is from Feb. 1 through Jan. 31, then the LOCCS report is due 30 days after each 6-month period of the grant.

Therefore, in this example, the first LOCCS submission would be for the period ending July 30 with the report due by Aug. 30. The next report would be due Feb. 28 for the period ending Jan. 31.

On the revised form, grantees will complete one worksheet per draw down and may continue to draw down funds per their usual periods -- either monthly or quarterly.

You will not have to submit anything to HUD prior to or following each monthly or quarterly draw down of funds. Each worksheet will list every expense incurred during that month or quarter and grantees will be required to maintain detailed expense documentation in their files.

The revised LOCCS voucher/expense report form will allow grant administrators to submit all eLOCCs-related information through one document.

Once approved, this report and submission schedule will replace all existing requirements pertaining to the submission of this form and copies of expense documentation.

While grant recipients may not be required to submit expense documentation on a regular basis, they will be required to maintain such documentation in their files.

HUD may request copies of this documentation at any time if additional program review is warranted. As always, failure to comply with program requirements will jeopardize your continued receipt of grant funds.

How to Comment

To submit comments, follow the instructions for formal comments as outlined in the Federal Register notice.

HUD program staff have indicated that only comments submitted via the formal procedure will be the reviewed and considered by HUD.

For copies of the proposed forms and other available information contact:
Carissa Janis
Office of Asset Management and Portfolio Oversight
U.S. Department of Housing and Urban Development
451 7th Street SW
Washington, DC 20410
202–402–2487.

Clarifications from HUD's Service Coordinator Program Specialist

Ms. Janis communicated with LeadingAge following the posting of this proposed revisions of the eLOCCS document for comment, and asked us to share the following clarifications based on questions she had received to date:

1. Grantees can continue to draw down from eLOCCS monthly or quarterly. Grantees choose either schedule and inform HUD when they want to make a change.

2. You will not have to submit anything to HUD prior to or following each monthly or quarterly draw down. eLOCCS will pay your request as long as your program is running appropriately and there is no need for more detailed departmental oversight.

3. Twice a year and on the same dates, you will submit the completed attached LOCCS voucher form/expense report. You will be required to complete one worksheet per draw down from eLOCCS in a 6-month period. Presumably you will complete each worksheet at the time of draw down. Completed forms will be due on a 6-month schedule according to each grant’s 12-month grant term. You will use your computer to fill out the Excel file and then email the file to your local field staff.

4. You will not have to submit expense documentation along with this form. You will be required to keep all such documentation on file. HUD staff may ask for copies at any time. HUD will not require you to submit expense documentation on a regular basis, unless specific issues of non-compliance have been identified and closer oversight is required for a designated period of time.

5. Any current procedures or documentation currently required by your local field staff will be replaced by the use and submission of this form. We will have one consistent policy and procedure throughout the country for reporting the use of grant funds.

6. As is always the case, failure to comply with program requirements (including the above proposed items) will jeopardize your continued receipt of grant funds.

According to Ms. Janis, in addition to the detailed instructions that the proposed form contains, HUD will in the next year or so issue updated written program guidance to help program administrators more easily manage the use of grant funds.

She also reiterated the request that all involved with the service coordinator program should sign up for HUD's Office of Multifamily Housing Service Coordinator Program Listserv.

The bill was funded at $6.8 billion less than the president’s request in order to comply with the budget caps set by sequestration.

The Section 202 account faced a drastic cut with the bill allocating just $414 million for the program and underfunding the amount needed for PRAC renewals.

Section 202 Demonstration Funding Rescinded

Unfortunately, in order meet necessary funding levels, the committee rescinded the demonstration funding from FY14, something LeadingAge, the Center for Aging Research, and many members have dedicated time to help shape in the hope of developing a more sustainable model for housing and services communities.

The committee also moved the Senior Preservation Rental Assistance Contract (SPRAC) renewals into the 202 account, rather than keeping them in the Project-Based Section 8 account where the president’s budget had moved them.

LeadingAge alerted members almost 2 weeks ago that the funding was cut and that the demonstration funds were rescinded to cover PRAC renewals.

Despite some initial confusion about the status of the demonstration project, the Appropriation Committee’s report made it clear that the Section 202 demonstration project funding of $20 million was rescinded, along with $20 million in capital advance funds, and $7 million in funds that will expire at the end of the FY15 to meet the PRAC renewal obligations.

The report states:

“HUD shall use a total of $47 million in uncommitted funds from prior year appropriations for the program. This includes $20,000,000 from an elderly demonstration program, $20,000,000 available from supportive housing capital advance program funds, and $7,000,000 in funds that will expire at the end of fiscal year 2015. The total appropriation plus uncommitted balances provide a total program level of $461,000,000, which will fully fund contract renewals and amendments in fiscal year 2016 for the elderly program. The Committee rejects the budget proposal to fund $16,000,000 of the section 202 program under the project-based rental assistance account and instead funds them under this heading.”

Rep. David Price (D-NC), THUD Subcommittee Ranking Member, noted the insufficient funding in the bill, and criticized the self-inflicted austerity imposed by the unrealistic budget caps set under sequestration.

Price offered an amendment to boost funding for transportation and housing programs including Section 202, and exceeding the caps, but it failed on a party-line vote.

Rep. Nita Lowey (D-NY), Appropriations Committee Ranking Member, highlighted the time wasted working on bills that underfunded critical programs.

Lowey reminded members that the sequestration levels made it impossible to pass bills on the House floor, and urged leaders to come together to work on an alternative to sequestration, as with the Murray-Ryan agreement 2 years ago to raise funding levels, so that they could pass real bills.

Rep. Barbara Lee (D-CA) also cited the value of affordable housing programs such as Section 202 and 811. Lee stated that the cuts pushed more and more Americans into poverty and homelessness.

What's Next

The bill now moves to House floor. According to Hill staff, a vote is expected in mid-June.

While the U.S. Senate has not released its THUD bill, the allocation is much lower and we expect the key affordable housing accounts to face additional cut.

You can help by Contacting Congress on the THUD bill.

LeadingAge Extends Deadline for Section 202 PRAC Preservation Survey (Alayna Waldrum, LeadingAge) - The LeadingAge Section 202 Project Rental Assistance Contracts (PRAC) Preservation Workgroup released a survey to collect crucial data to help quantify the issues that cannot be funded under the PRAC projects' current reserve plan and funding in April 2015. In order to collect a statistically significant number of responses the deadline had been extended to June 30, 2015. Please click here to view the survey.

The report created by the survey responses will allow the workgroup to work with the U.S. Department of Housing and Urban Development (HUD) and Congress to address the preservation challenge for PRACs under the extreme fiscal constraints that domestic spending faces.

About the PRAC Preservation Workgroup

In February 2015, LeadingAge launched a Section 202 PRAC Preservation workgroup to "research the current and future physical needs of Section 202 PRAC inventory, develop a comprehensive preservation strategy for these properties, prepare a legislative proposal for members of Congress, and engage in an education and advocacy campaign to secure support."

The workgroup will focus on those projects built since 1990 under the Capital Advance grant program.