Is there any guidance regarding PIC-NG for Emergency Housing Vouchers (EHV)?
Summary: Emergency Housing Vouchers (EHV) funds allocated to the PHA for HAP (both funding for the initial allocation and HAP renewal funding) may only be used for eligible EHV HAP purposes.
EHV HAP funding obligated to the PHA may not be used for EHV administrative expenses or the other EHV eligible expenses under this notice. Likewise, EHV administrative fees and funding obligated to the PHA are to be used for those purposes and must not be used for HAP.
WHAT EHV FUNDS MAY AND MAY NOT BE USED FOR:
The appropriated funds for EHVs are separate from the regular HCV program and may/may not be used in the following ways:
- Similar to the Mainstream program, these funds may not be used for the regular HCV program, but may only be expended for EHV eligible purposes.
- EHV HAP funds may not roll into the regular HCV restricted net position (RNP) and must be tracked and accounted for separately as EHV RNP.
- EHV administrative fees and funding for other eligible expenses permitted by this notice may only be used in support of the EHVs and cannot be used for regular HCVs.
- EHV funding may not be used for the repayment of debts or any amounts owed to HUD by HUD program participants including, but not limited to, those resulting from Office of Inspector General (OIG), Quality Assurance Division (QAD) or other monitoring review findings.
EHV FUNDING & HUD:
HUD will update the Voucher Management System (VMS)
This will be used to collect aggregate data from participating PHAs on a monthly basis that is consistent with other programs under Section 8(o) of the United States Housing Act of 1937. This data will initially be used to track leasing and cost data and to reconcile funds advanced to participating PHAs against actual expenditures reported.
HUD plans to leverage PIC-NG, the new information technology platform developed for the MTW Demonstration program’s expansion , to collect EHV tenant information as opposed to using the existing legacy IMS/PIC system.
For more information on MTW, see https://smcocpa.com/moving-to-work/.
HUD expects to issue a streamlined Form 50058 in the near future
This will allow HUD to pay monthly HAP and administrative fee disbursements based on that information.
Once the new application and processes are implemented, HUD plans to reduce or eliminate VMS reporting requirements for the program.
Additional information will be forthcoming on PIC-NG rollout and implementation requirements including expedited timelines for tenant characteristics reporting.
PHAs do not report into IMS/PIC for EHV families. In the meantime, in order to account for and track the use of the EHV funding, PHAs must comply with the following reporting and financing record requirements:
- VMS – Because EHVs are funded from a separate appropriation than the regular HCVs, HUD will modify VMS to track the multiple data points for EHVs from participating PHAs. The PHA must enter the data on a monthly basis into VMS. These reporting requirements also apply to MTW agencies.
- FDS – HUD’s Uniform Financial Reporting Standards (UFRS) Rule (24 CFR § 5.801) requires PHAs that administer the Section 8 programs to submit annual financial data to HUD. Specifically, UFRS requires that the financial data is: 1) prepared in accordance with Generally Accepted Accounting Principles (GAAP) as further defined by HUD in supplementary guidance; 2) submitted electronically to HUD through the internet; and 3) submitted in such form and substance as prescribed by HUD.
HOW IT WORKS – SUBMITTING FINANCIAL INFORMATION TO HUD’S FASS-PH:
To meet the goals of the UFRS rule, PHAs are required to submit their financial information to HUD’s Financial Assessment Sub-system for Public Housing (FASS-PH). PHAs are required to submit this financial information in a prescribed format, the Financial Data Schedule (FDS) (also referred to as Public Housing Financial Management template).
Financial information collected in the FASS-PH system includes the reporting of the receipts, uses, and balances of all PHA funds regardless of the funding source (i.e., entity-wide reporting). This financial information is reported at the funding source level.
As a separate funding source, the ARP supplemental funding for the EHVs must be reported separately on the FDS. The default reporting level is at the Catalog of Federal Domestic Assistance (CFDA) level. However, when a CFDA number does not exist or is not applicable, HUD will provide a program number under which the PHA should report its financial information.
Due to the likely one-time appropriation of the supplemental funds provided under ARP, CFDA numbers for these EHV funds will not be issued. However, HUD must still meet its monitoring responsibilities and provide transparency in the PHAs’ receipts and uses of EHV supplemental funding. Thus, HUD recommends that PHAs establish a separate general ledger for the program or at the very least provide subsidiary details under the existing HCV program sufficient to provide the necessary information in the FDS.
Rather than have PHAs report under the generic Federal Program columns that are already established in the FASS-PH system (e.g., Federal Program 1, Federal Program 2), the Real Estate Assessment Center (REAC) has established a new column on the FDS for reporting EHV supplemental funds. REAC will publish specific guidance on revenue recognition in a future notice.
What additional fees will PHAs qualify for under EHVs?
PHAs that accept an allocation of EHVs will receive fees in addition to ongoing administrative fees to assist in the facilitation and leasing of the EHVs. Additional fees include:
- Preliminary Fees – $500 will be awarded per allocated EHV. Issuing Fees – Participating PHAs will earn $100 once the voucher is initially leased, provided the PHA reported the issuance of the EHV in the Public Housing Information Center-Next Generation (PIC-NG) system within 14 days of the later of the effective date of the family’s EHV or when the system becomes available for reporting.
- Placement Fees – PHAs will be awarded $500 for each EHV family placed under a HAP contract no later than 4 months of effective date of the ACC funding increment. For each EHV family placed under a HAP no later than 6 months after the effective date of the ACC funding increment, PHAs will receive $250.
- Ongoing Admin Fees – PHAs will receive the full column A admin fee amount. Services Fee – For each allocated EHV, PHAs will receive $3,500 that must initially be used for the services fee eligible uses defined in PIH Notice 2021-15. The Services Fee can be used for:
- Housing search assistance
- Tenant fees including security and utility deposit assistance, rental application fees, and holding fees
- Owner recruitment and outreach as well as incentive and retention payments, and
- Other eligible uses to help families successfully lease, up, including moving expenses, tenant-readiness services, essential household items, and renter’s insurance if required by the family’s lease.
The above information was derived from HUD guidance in its May 19th FAQ as well as PIH Notice 2021-05. Additional information can be found in these documents for the EHV program.
Contact Smith Marion & Co. PHA experts for further assistance 909-307-2323 or firstname.lastname@example.org.
Doug Englehart, MSA, CPA