REVISED HUD FORM DISCUSSION 2016 MTW CONFERENCE APRIL 22, 2016 April Buzby, Keene Housing Sheryl Stansell, Tacoma Housing Authority Martha Tai, Cambridge Housing Authority

HUD FORM TIMELINE May 21, 2013Current Form Issued March 1, Day Notice Released May 2, 2016Comments Due May 2, 2016Current Form Expires

KEY CHANGE MTW “Households Served” (pps. 2-3) CurrentProposed Federal MTW Public Housing Units LeasedMTW Public Housing Units Leased Federal MTW Voucher (HCV) Units UtilizedMTW Housing Choice Vouchers (HCVs) Utilized Units Occupied/Leased through Local, Non- Traditional MTW Activities Local, Non-Traditional: Tenant-Based Local, Non-Traditional: Property-Based Local, Non-Traditional: Homeownership Households Served through Local, MTW Funded Non-Traditional Services Only Households Receiving Services Only **Explicitly states these households do not count towards StS (“Total Households Served/Units Leased”) determination**

KEY CHANGE Use of Standard Metrics (p. 3) …After review of the proposed activity, HUD will determine the Standard HUD Metrics that the MTW PHA must provide. After the activity has been approved, HUD will advise the MTW PHA of any necessary changes to the applicable Standard HUD Metrics.

GENERAL CHANGE Use of Standard Metrics (p. 4) “[A]n approved activity must be closed out in an Annual MTW Report. If an Annual MTW Plan is to be submitted after the MTW PHA has decided to close the activity but prior to the submission of an Annual MTW Report, the to-be-closed activity should be listed in the ‘Not Yet Implemented Activities’ or the ‘Activities On Hold’ subsection of the Annual MTW Plan as applicable. The associated discussion and timeline should indicate that the MTW PHA will close out the activity in the next Annual MTW Report.”

GENERAL CHANGE Housing Stock Information (pps. 8-9) New Table Anticipated Existing Project Based Vouchers at the End of the Plan Year Tenant-based vouchers that the MTW PHA is currently project-basing in the Plan Year. These include only those agreements in which a Housing Assistance Payment (HAP) Agreement will be in place by the end of the Plan Year. New Snapshot data is explicitly stated as acceptable methodology. Anticipated Number of Households Served in the Plan Year Waiting List Information Leasing – Actual Number of Households Served

GENERAL CHANGE Statutory Objectives and Requirements (p. 12) MODIFIED 75% OF FAMILIES ASSISTED ARE VERY LOW INCOME - Table reformatted based on 4 income bands instead of current 3 bands. Previous FY numbers have been removed. Proposed MTW Activities (p. 15) SIMPLIFIED ACTIVITY DESCRIPTION COMPONENTS NEW SECTION C. COST IMPLICATIONS State if proposed activity will result in any cost implications (positive and/or negative). If not, provide an estimate and discuss how anticipated surplus or deficit will be managed.

GENERAL CHANGE Rent Reform (p ) MODIFIED MINOR CHANGE IN HOW RENT REFORM IS DEFINED. CurrentProposed …any change in the regulations on how rent is calculated for a household. Any policy that an MTW PHA enacts that alters the rent calculation would be considered a type of rent reform…. …any change to how rent/tenant share is calculated for a household that would not be allowable absent the MTW activity. Any MTW activity that an MTW PHA enacts that alters the rent calculation (the amount a household contributes towards their housing costs) would be considered a type of rent reform. Modified wording from “should” to “must” Hardship Case Criteria Description of Annual Reevaluation

GENERAL CHANGE Approved MTW Activities – Report (p ) Modified Implemented Activities section Asks for details regarding “Annual Reevaluation”… put in place when proposing the MTW activity. Reworded description parameters of activity changes, benchmarks and metrics with “Actual Significant Changes” and “Actual Changes to Metrics/Data Collection)”. Requires new information in “Challenges in Achieving Benchmarks and Possible Strategies”.

GENERAL CHANGE Sources and Uses (p. 21) NEW DESCRIBE PLANNED USE OF MTW SINGLE FUND FLEXIBILITY The MTW PHA shall also provide a thorough description of how it plans to use MTW single fund Flexibility to direct funding towards specific housing and/or service programs in a way that responds to local needs (that is, at a higher or lower level than would be possible without MTW single fund flexibility). REMOVED COMMITMENT OF UNSPENT FUNDS SECTION

GENERAL CHANGE Administrative (p. 23) NEW SECTION E. LOBBYING DISCLOSURES Signed copies of the Lobbying Certification (SF-LLL) and the related Lobbying Disclosure (50071) required in the Plan. SIMPLIFIED FORMAT Separate excel versions of Sections II and VI no longer required (p. 1) SIMPLIFIED SUBMISSION All submissions must be sent in electronic format via (p. 1).

GENERAL CHANGE Standard HUD Metrics (pps ) MODIFIED METRIC HUD MetricCurrentProposed CE#5: Increase in Agency Rental Revenue Rental revenue in dollars (increase) Total Household contribution towards housing assistance (increase) SS#7: Increase in Agency Rental Revenue

SOLICITATION OF PUBLIC COMMENT (1)Whether the proposed collection of info is necessary for proper performance of functions of the agency, including whether the information will have practical utility (2)The accuracy of the agency’s estimate of the burden of the proposed collection of information: NO

SOLICITATION OF PUBLIC COMMENT (3) Ways to enhance the quality, utility, and clarity of the information to be collected; and (4) Ways to minimize the burden of the collection of information on those who are to respond; including through the use of appropriate automated collection techniques or other forms of information technology, e.g. permitting electronic submission of responses.

CORE CONCERNS WITH Standard HUD Metrics Current methodology forces metrics that are irrelevant to the activity and collectively do not provide an accurate representation of all MTW activities. Some metrics requires force PHAs to populate numbers that cannot be verified o HCV Household contribution towards housing assistance Not calibrated to account for different markets (e.g. staffing costs and HAP vary)

CORE CONCERNS WITH Standard HUD Metrics Baseline values may be arbitrary Benchmarks are set on an annual basis – what are we comparing over time? Initial year outcomes can vary dramatically from subsequent years. Success in subsequent years may be flatline outcomes, yet appear misleading to the public. Attaining self-sufficiency needs to factor local markets. Average and median outcomes need to be considered.

CORE CONCERNS WITH Methodology for Households Served needs more flexibility to reflect the MTW authority and resources dedicated to services. HUD recognizes that an activity may be advancing one MTW goal while working against another (e.g. a self-sufficiency activity may require more services and greater administrative burden). This should be indicated and inform metrics.

NEXT STEPS List of core concerns to distribute to MTW agencies.

QUESTIONS April Buzby, position Keene Housing Phone Sheryl Stansell, position Tacoma Housing Authority Phone Martha Tai, Senior Program Manger Cambridge Housing Authority