Rental Housing Reform
Transformation of Rental Assistance
HUD Secretary Shaun Donovan has launched an initiative to recapitalize public housing and update how HUD rental assistance programs are organized and administered.
For participating public housing properties, the HUD initiative would address a long-standing capital needs backlog in the public housing inventory by shifting capital and operating subsidies to a single rental subsidy stream aimed at attracting low-income housing tax credit and other capital from private and other public sources.
The initiative would also streamline HUD’s project-based rental assistance programs. HUD currently operates numerous separate rental assistance programs—by one count, 13 such programs. The current scheme is inefficient and cumbersome, both for HUD, which administers the programs, and for those who, like SAHF members, own, operate, and develop affordable housing properties in multiple states, under various HUD program authorities. More information.
Reinvention of the Section 202 Program-Housing for Low-Income Elderly
HUD’s Section 202 program has a distinguished history of providing quality housing to low-income seniors since 1959. Over the last three decades, however, the program has produced progressively fewer apartments in ever smaller properties, making it especially difficult for providers to meet the needs of seniors cost-effectively and at scale. Accordingly, over the last two years, HUD has undertaken to re-envision the program as providing the platform for meeting the needs of frail seniors. Broadly, under HUD’s approach, the operating subsidy would switch from a Project Rental Assistance Contract that covers only operating expenses coupled with a capital grant to a project-based, long term rental assistance contract at market rents, enabling the sponsor to borrow some of the capital and to combine it with capital from other sources, including the low-income housing tax credit. Instead of being the principal source of capital, HUD's capital contribution would be gap financing, to the extent necessary to supplement private, state and local debt and equity.
On April 2, 2010, SAHF and LeadingAge (formerly AAHSA) outlined in a letter to HUD their recommendations for an improved Section 202 program. More information. Both organizations have been outspoken and influential advocates for creating an opportunity to combine Section 202 and other capital funding for bricks and mortar with HHS program funding for predictable, long-term mainstream services in a way that serves low-income seniors effectively and cost-effectively.
In October, 2010, HUD sought comment on a more detailed version of the revised program. SAHF, Leading Age/AAHSA, and Enterprise Community Partners provided detailed comments on how best to make the program work well with low-income housing tax credits. More information.
SAHF's Administrative Recommendations to HUD
There have been many years of pent-up need to revise or update HUD regulations and other policy guidance. To assist in that process, SAHF, in conjunction with the National Housing Trust (NHT) and the Housing Partnership Network, developed a list of action items that HUD could implement without legislation. To review the list of administrative items SAHF is pursuing, please click here.
To-date SAHF has completed and submitted to HUD the following memorandums:
- Section 8 Renewal Guide-Proposed Chapter 15 Improvements:
Explanation of Proposed Changes
Redline of Changes and Explanatory Comments
SAHF's Comments on the Section 8 Renewal Guide - Efficiency Consolidation
- Secondary Seller Financing in FHA Programs
- Uses of Residual Receipts in Projects Governed by the 1979/80 Section 8 Regulations
- Transfers of M2M Restructured Projects to Qualified Nonprofit Purchasers
- Continuation of Section 236 IRP Payments in Cases of Unit Reduction or Changed Unit Mix
The two following memorandums relate to energy conservation in HUD multifamily housing. Each is designed to suggest practical steps that could encourage conservation and reduce costs.