On April 10, 2020, the U.S. Department of Housing and Urban Development (HUD) released a series of temporary waivers and alternative methods due to COVID-19 that Public Housing and Community Development (PHCD) has adopted. These temporary waivers will allow PHCD to limit contact with residents and participants and to continue housing families and keeping families in their home. As a result, below is the list of temporary waivers PHCD has adopted:
1. Self-Certifications During Annual and Interim Reexaminations:
Accept self-certifications to verify family composition, income, assets, and expenses when a family is unable to obtain third party verification of such due to Covid-19. The resident may provide this verification by email, fax or regular mail.
This waiver is available until 12/31/20.
How does this waiver affect you?
Current regulations prescribe a verification hierarchy that PHCD must fellow when requesting information to verify information provided by the family. If you are unable to provide the required information, this waiver allows us to move forward with you Annual or Interim reexamination based on the information you provide. However, the information you provide can later be re-verified and you may be held responsible for any discrepancies. Therefore, please remember to provide complete and accurate information at all times.
2. Voucher Oral Briefing
Allows alternative methods to conduct required voucher briefing (e.g., telephone, virtual meetings, etc.).
How does this waiver affect you?
Current regulations require that we inform you about the program through an oral briefing and through written information. This waiver allows us to comply with that requirement by providing you information over the phone, online, or through other alternative methods in order to not delay the issuance of your voucher.
3. Term of Voucher -Extensions of Term
Allows PHCD to provide voucher extensions regardless of current policy.
How does this waiver affect you?
Current regulations require that we provide voucher extensions of search time based on existing agency policies. Currently, our policies limit extensions to 30 days or additional time as a reasonable accommodation for a person with disabilities. This waiver allows us to grant additional time for families affected by COVID-19.
4. Absence from Unit
Allows for PHCD discretion on absences from units longer than 180 days.
How does this waiver affect you?
Some residents may have needed emotional or medical support that
required them to be absent from the unit longer than 180 days. This waiver
allows us evaluate these absence on a case-by-case basis and determine if the
absence is allowable. However, in all cases, families are required to report
their absence as soon as practicable.
5. Automatic Termination of the Housing Assistance Payment (HAP) Contract
Allows PHCD to extend the period of time after the last HAP payment is made before the HAP contract terminates automatically.
How does this waiver affect you?
Current regulations state that the HAP contract automatically
terminates after 180 days of non-payment by the PHA. This usually happens when
the unit is under an abatement for extended period of time or when the family’s
share of the rent exceeds the contract (among other reasons). This waiver
allows us to review these contracts and provide additional time in order to
prevent termination of the HAP contract.
6. Utility Allowance Schedule – Required Review and Revision
Provides for delay in updating utility allowance schedule.
How does this waiver affect you?
All families that are responsible for paying for their utilities automatically receive an allowance, a deduction, from their portion of the tenant rent to owner. Current regulations require that we update the schedule of allowances once a year if there is a change in utility rates by more than 10%. Although we do not foresee a delay in our ability to update the schedules this year, we are implementing this waiver and notifying you of the effect of any delay. If there is a delay, you will continue to receive your current allowance until your next regularly scheduled annual reexamination.
7. Homeownership Option – Homeownership Counseling
Waives the requirement for the family to obtain pre-assistance counseling.
How does this waiver affect you?
Current regulations require that families interested in the Homeownership option of the program go through pre-assistance counseling. COVID-19 has impacted provider’s ability to provide this assistance so HUD is allowing us to waive this requirement. This means that families pursuing the Homeownership option can continue the process. All other Homeownership requirements remain the same.
8. Initial Inspection Requirements
Allow owner to certify that there are no life-threatening deficiencies. If self-certification was used, PHCD must inspect the no later than October 31, 2020.
How does this waiver affect you?
Current regulations require that PHCD inspect a unit prior to
entering into a Housing Assistance Payment (HAP) contract. PHCD continues to
perform initial inspections using protective measures recommended by the Center
for Disease Control (CDC). However, PHCD is implementing this waiver to reserve
its discretion and its sole-discretion to not require the initial inspection and
allow the move-in based on the owner’s certification that there are no
life-threatening deficiencies. However, in all cases where an exception is
made, PHCD will inspect the unit prior to October 31, 2020.
9. Project-Based Voucher Pre-HAP Contract Inspections
Allow owner to certify that there are no life-threatening deficiencies. If provided by owner, PHCD will conduct a follow-up inspection no later than October 31, 2020.
How does this waiver affect you?
Current regulations require that PHCD inspect a unit prior to entering into a Project-Based Housing Assistance Payment (HAP) contract. PHCD continues to perform initial inspections using protective measures recommended by the Center for Disease Control (CDC). However, PHCD is implementing this waiver to reserve its discretion and at its sole-discretion to not require the initial inspection and allow the move-in based on the owner’s certification that there are no life-threatening deficiencies. However, in all cases where an exception is made, PHCD will inspect the unit prior to October 31, 2020.
10. Non-Life-Threatening Deficiencies
Allows for extension of up to 30 days for owner repairs of non-life threatening conditions.
How does this waiver affect you?
Current regulations require that PHCD inspect the correction of deficiencies within 30 days of the deficiency being reported. In addition to extensions allowed under existing policies, this waiver allows us to grant an additional 30 days for owners to correct non-life threatening deficiencies. Implementing this waiver means, among other things, that we can better respond to families who have a vulnerable member and want to reduce the risk of exposure to COVID-19 by a person entering their home to perform repairs.
11. Interim Inspections
Allows PHCD to use alternative methods to conduct interim inspection and verify repairs.
How does this waiver affect you?
Implementing this waiver allows us to verify that repairs were made using alternative methods. Although PHCD perform any inspections using protective measures recommended by the Center for Disease Control (CDC), this waiver allows us to use video, receipts, and other methods to verify deficiencies are corrected. The method allowed will be determined by PHCD, in its sole discretion, on whether or not the deficiency can be verified through an alternate method.
12. Project-Based Voucher Turnover Inspections
Allows for Project-Based Voucher turnover units to be filled based on owner certification there are no life-threatening deficiencies. Allows for delayed of the full HQS inspection.
How does this waiver affect you?
Current regulations require that PHCD inspect a unit prior to
allowing a move-in to a Project-Based Voucher Unit. PHCD continues to perform
initial inspections using protective measures recommended by the Center for
Disease Control (CDC). However, PHCD is implementing this waiver to reserve its
discretion and at its sole-discretion to not require the initial inspection and
allow the move-in based on the owner’s certification that there are no
life-threatening deficiencies. However, in all cases where an exception is
made, PHCD will inspect the unit prior to October 31, 2020.
13. HQS Space and Security
Waives the requirement that each dwelling unit have at least 1 bedroom or living/sleeping room for each 2 persons.
How does this waiver affect you?
Some families have grown through the pandemic because of a birth
or through legal instruments such as marriages and adoptions. In some cases,
the family’s size exceeds occupancy standards permissible under existing
regulations. By implementing this waiver, PHCD would not require the family to
immediately move to a more appropriate size unit.
14. Homeownership Option – Initial HQS Inspection
Waives the requirement to perform an initial HQS inspection in order to begin making homeownership assistance payments, however, the family must obtain independent professional inspection.
How does this waiver affect you?
Current regulations require that PHCD inspect a unit prior to making homeownership assistance payments. PHCD continues toperform initial inspections using protective measures recommended by the Center for Disease Control (CDC). However, PHCD is implementing this waiver to reserve its discretion and at its sole-discretion to not require the initial inspection and allow assistance to begin based on a separate independent professional inspection.
Please contact us at 305-403-3222 with any questions or concerns regarding this Notice.