On April 7, HUD PIH released two Notices (Notice PIH-2016-05 and Notice PIH-2016-06) containing implementation guidance on the Streamlining Final Rule that went into effect on April 7. Published on March 8, 2016, the final streamlining rule contains 16 provisions. All of the provisions touch on programs administered by HUD’s Office of Public and Indian Housing (PIH); some of the provisions apply as well to multifamily programs administered by HUD’s Office of Housing and/or HUD’s Office of Community Planning and Development (CPD). Both Notices address provisions only as they apply to programs administered by public housing agencies (PHAs).
Notice PIH-2016-05, Streamlining Administrative Regulations for Programs Administered by Public Housing Agencies, addresses each provision found in the Streamlining Final Rule and either provides direct implementation guidance or refers the reader to other implementation resources. Each provision is included as a separate attachment in the Notice and discusses the regulation; the programs to which the provision applies; a description of the change included in the Streamlining Final Rule; whether adoption of the change is mandatory or discretionary and whether the change requires an amendment to a PHA’s Admissions and Continued Occupancy Policy (ACOP), its Administration Plan, or both prior to implementation; and the effective date of the provision. Provisions included as amendments discussed in the guidance include: verification of Social Security Numbers; definition of extremely low-income families; exclusion of mandatory education fees from income; streamlined annual reexamination for fixed sources of income; the earned income disregard; family declaration of assets under $5,000; utility reimbursements; public housing rents for mixed families; tenant self-certification for CSSR; public housing grievance procedures; biennial inspections and the use of alternative inspection methods; Housing Quality Standards reinspection fee; exception payment standards for providing reasonable accommodation; family income composition: regular and interim examinations; and utility payment schedules.
Notice PIH-2016-06, Administering the Self-Certification Flexibility when Verifying Community Service and Self-Sufficiency Requirement (CSSR) Compliance, contains information for PHAs that elect to allow residents to self-certify their CSSR as permitted by the Streamlining Final Rule. This includes: updating PHA policies that permit the acceptance of self-certification prior to allowing residents to self-certify; submitting an annual notification to residents informing them of their ability to self-certify; establishing sampling methodology and validation requirements that include third-party verification of self-certifications that occur at a point in time annually; treating fraudulent self-certification; and HUD oversight.
For more information, see NAHRO’s analysis of the Streamlining Final Rule in the March 15 Monitor: http://www.nahro.org/node/403/year/2016/month/3/date/0#11376.
Read this update online here.