MHDA Spring Conference 2013 Chandra Broadnax, Program Analyst Detroit Field Office PIH

PHA Plan Process  Established by Section 5A of the United States Housing Act of 1937 (42 U.S.C et seq.). Section 5A(b) of the U.S. Housing Act of 1937 (42 U.S.C. 1437c- 1(b))  Amended by the 2008 Housing and Economic Recovery Act (HERA), Sections 2701 and 2702, Small Public Housing Authorities Paperwork Reduction Act.

Related information  PIH Notice Provides guidance for the process of PHA Plans Implements Title VII ○ Qualified vs Non-Qualified PHAs Implements revised PHA Plan templates Implements revised Certifications

HERA  Signed July 30, 2008  Provided exemptions for Qualified PHAs  Provided revised FO review protocol for Qualified PHAs The Detroit Field Office is not required to review annual plans submitted by Qualified PHAs

Two Categories of Distinction Qualified PHAs Non-Qualified PHAs  Less than 550 Units  Not Designated troubled under PHAS  No failing SEMAP during the prior 12 months Any PHA that doesn’t meet those thresholds

How Do I know if I am Qualified?  HUD posts the Qualified PHA list on HUD.GOV  If you have any questions contact your PHRS

Am I still Qualified?  What if my status changes after the "Qualified" PHA list is posted on the PHA Plan webpage? Your PHA will continue to be monitored pursuant to the posted rating until a new list is published

Why a PHA Plan? Strategic Planning Needs Programs & Policies GoalsBudget Tenants, Community and Quality of Life

Basic Components of a PHA Plan 1. Five Year Plan Every Fifth Year regardless of designation 2. Annual Plan Every Year if unqualified or troubled Certifications are still required annually

Five Year Plan  First submission required in 2000  Guidance and Regulation PIH , III.B.8 24 CFR CFR 903.6

Changes or Amendments to the Five Year Plan  Per 24 CFR You may amend or modify the Five Year Plan If the change is outside of the previously submitted/approved substantial deviation, you must comply with initial submission requirements of the plan (including timelines) i.e. ○ RAB, Consistency with the Consolidated Plan, 45-Day Public Review, Board Resolution, Official submission and review by HUD

Substantial Deviation/Significant Amendment  Substantial Deviation At your discretion You must state basic criteria in the annual plan Definition must be included in Section 10 ○ Or provided as an attachment  PIH Changes to rent or admissions policies or organization of the waiting list; Additions of non- emergency work items not previously included Change in use of replacement reserve funds under CFP Any change in demo/dispo Any change in homeownership Any change in conversion

What if there are changes to the approved 5 YR Plan? On an as-needed basis, you can submit a revised plan ○ Changes are outside of the significant deviation or significant amendment/modifications to the approved CFP Five-Year Action Plan. ○ The actual difference in costs, work items, etc. would need to be determined in the deviation

Discussion on Field Office Review Process

What to Submit and Where to Submit it Form/Certification Submission Method to HUD HUD /Mail HUD /Mail HUD 50075PHA Plan Website HUD PHA Plan Website HUD PHA Plan Website HUD CR /Mail HUD /Mail Form SF-LLL /Mail HUD SL /Mail

Submission Due Dates FYE (Fiscal Year Ending) FYB (Fiscal Year Beginning) Due Date 12/31Jan 1, 2013Oct 18, /31April 1, 2013Jan 16, /30July 1, 2013April 17, /30Oct 1, 2013July 18, 2013

PHA Plan Review Any questions regarding PHA Plans can be directed to your assigned PHRS PHA Submits initial or subsequent version of PHA Plan to PHA Plan Website PHA Plan Coordinator pulls plan/tracks submission date PHA Plan Coordinator Alerts the PMT Team & Review begins PHRS conducts the Field Office Review Process FM Review FA Review Director Signs letter and PHA is notified of approval or identified deficiencies If approved, PHA Plan Coordinator posts to PHA Plans Website Entire Process should take 75- Days or less

Question and Answer

Five Year Plan/Annual Plan and GPNA  Question- When is my GPNA submittal due? Do I have to complete the GPNA before I do my next PHA Plan? Answer – Depends…  Question- Do I have to do a GPNA even if I do not have enough money to make all of the improvements? Answer – Yes, it is the basis as contained in the PHA Plan

Five Year Plan/Annual Plan and GPNA  Question- Am I required to include each and every ECM in my Capital Fund 5-year and annual plans? Answer – No, only those energy conservation measures (ECMs) for which you have funds

Q & A / Resources

Brief HUD Updates  PIH Notice Emergency Safety& Security Funding (5/3/2013) Applications due by June 19 th, 2013 ○ This year, Congress appropriated $20 million in funding to provide assistance to “public housing agencies for emergency capital needs including safety and security measures necessary to address crime and drug-related activity as well as needs resulting from unforeseen or unpreventable emergencies and natural disasters excluding Presidentially declared disasters occurring in fiscal year [2013]  PIH (3/5/2013) Agreements with Responsible Entities and Timing for Environmental Reviews

Brief HUD Updates  PIH (2/4/2013) Radon Information For PIH Programs  PIH (1/28/2013) Guidance on Verification of Excluded Income  PIH (1/22/2013) Public Housing and Housing Choice Voucher Programs – Temporary Compliance Assistance (FAQ posted on 3/1/2013)

HUD.GOV Resources  PHA Plan/Five Year Plan/Annual Plan- ha  EPIC & Five Year Plan/Annual Plan- ograms/ph/capfund/epic  PNA/GPNA- ms/ph/capfund/physicalassessment  GPNA Tool- ms/ph/capfund/gpnatool  Notices, Rules, & Regulation- ions/notices  PIH News to Use – nounce