Today, HUD issued a notice announcing a 60-day solicitation of public comment on the proposed Affirmatively Furthering Fair Housing Assessment Tool for States and Insular Areas (AFH Tool). The proposed AFH Tool will be the vehicle by which states and insular areas will prepare and submit their Assessment of Fair Housing (AFH), as required by the AFFH final rule. The AFH replaces the prior fair housing planning process, called the analysis of impediments. The proposed AFF Tool will also be used for AFHs conducted through joint or regional collaborations (with local governments and/or Public Housing Authorities [PHAs]) where the state is the lead entity.

HUD is particularly interested in soliciting comments on joint collaborations between States and Qualified PHAs (PHAs with a combined unit total of 550 or less and are not designated as troubled under the Public Housing Assessment System [PHAS] or do not have a failing score under the Section 8 Management Assessment Program [SEMAP]). Comments on the AFH Tool must be filed electronically at by May 10, 2016.

The AFH Tool is one of three fair housing Assessment Tools that HUD has committed to issuing. The other two include the Local Government Assessment Tool, which was finalized for use on December 31, 2015, and the PHA Assessment Tool. The former is to be used by local governments, or by joint and regional collaborations (with local government(s) and/or with one or more PHA partners) where the local government is the lead entity. The latter will be used by PHAs or collaborating PHAs. The Department has indicated that the 60-day public comment notice for the proposed PHA Assessment Tool will be issued in the very near future.

Even though HUD published the solicitation of comment for the AFH Tool today, the actual AFH Tool has not yet been made available to the public. Currently, HUD’s notice provides descriptions of the AFH Tool, including its objectives and structure, which largely mirror the Local Government Assessment Tool, but with key differences:

  • The AFH Tool expands the area of analysis that pertains to Low-Income Housing Tax Credits (LIHTC) and the state’s Qualified Allocation Plan and includes additional questions to other State-administered programs that relate to housing and urban development.
  • The AFH Tool includes questions that will elicit a fair housing analysis for Qualified PHAs that will “sufficiently address fair housing issues, contributing factors, goals and priorities relating to the PHA’s service area and region.”

HUD is strongly encouraging joint AFH submissions and is requesting feedback on how to best encourage and facilitate collaborative participation between states and Qualified PHAs. According to HUD, the questions addressed to Qualified PHAs that collaborate with states using the proposed AFH Tool will differ, and may be less burdensome, than the questions contained in the forthcoming proposed PHA Assessment Tool. Qualified PHAs that collaborate are also expected to experience cost savings as these program participants may take advantage of the state’s regional analysis to fulfill their own regional assessment portion within the AFH Tool. HUD is also requesting comments from small entities, such as Qualified PHAs, on how to reduce the burden of the AFH–while still achieving the necessary fair housing analysis–and to what extent small entities expect to rely on outside resources when conducting a collaborative AFH with a state.

While not yet available at the time of this writing, HUD expects to soon post the instructions that will accompany the AFH Tool, a chart comparison of the AFH Tool and the Local Government Assessment Tool, and sample maps and tables online at hudexchange.infoand HUD states that it will post sample maps and tables for the AFH Tool no later than March 18, 2016.

HUD’s notice largely pertains to the AFH process required by lead States and Insular Areas, a substantial portion of the notice requests feedback from PHAs. NAHRO is strongly encouraging PHA members to read through the notice and share their questions and concerns with NAHRO staff: Jenny Hsu (, Eric Oberdorfer (, or Tushar Gurjal (

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