Though the federal government partially (mostly) shut down from October 1-16, the U.S. Department of Housing and Urban Development (HUD) and other federal employees returned to work according to their regular schedule beginning Thursday, October 17.
Details on the Congressional action leading to this are covered elsewhere. In a nutshell, however, the government is funded through Jan. 15th, the debt ceiling has been raised through February7, and most HUD operations should resume as normal.
Because it technically expired at the end of FY13, the preservation-focused Rental Assistance Demonstration (RAD) has been extended through January 15. And, during the shutdown, the deadline for the Service Coordinator NOFA was extended to November 16, 2013, to match the ALCP NOFA deadline (and move review of applications outside of the potential shutdown timeframe).
Multiple, Short-Term Funding Allocations May be Required to Cover Rental Subsidy Payments
Given the short-term nature of extensions under a Continuing Resolution, and funding formulas used, there is still some question about the manner in which HUD will extend or renew rental assistance funding and contracts.
Based on previously allocated FY13 funding, HUD expects there is already sufficient funding allocated to cover all existing contracts for the month of November. As detailed in their shut-down contingency plan and FAQ, "HUD will make payments under Section 8 and Project Rental Assistance Contracts where there is a permanent or indefinite authority or multi-year funding, or where there is budget authority available from prior year appropriations or recaptures."
Just before the shut-down ended, HUD was gearing up to return to the HUBs sufficient staff to handle Section 8 and PRAC renewals for expiring contracts and processing amendment funds for non-expiring Section 8 contract renewals.
But going forward, there is some question as to the length of time for which HUD will be able to commit funding to existing or renewed contracts. Details are being worked up, and we'll get information to you as soon as it is available.
Essentially, however, it is likely that subsidy contracts will again become subject to having a series of small allocations applied to them throughout the coming months or remainder of the fiscal year. Hopefully the process will be seamless from the provider side.
REAC Operations Resume; Make-up Inspections Scheduling Begins
LeadingAge also checked in with HUD Real Estate Assessment Center staff to determine the status of REAC operations, and expecations regarding physical inspection scheduling. Deputy Director Delton Nichols provided the following detailed response:
- The Technical Assistance Center just opened back up today (10/18/13); therefore, physical inspections are to commence as of today.
- For properties that had inspections scheduled between October 1 and 17 that were not able to be conducted, inspectors will contact the properties to reschedule them.
- We have changed the policy concerning no inspections during the weeks of Thanksgiving, Christmas, and New Year's. In the past there were no inspections during these weeks; however, going forward if a property wants an inspection during these weeks they can be scheduled as long as they are not scheduled on the actual holiday. If a property does not want an inspection scheduled during these weeks they should simply state that to the inspector when she/he contacts the property and the inspector will not schedule an inspection during these times.
- We have not completed the full impact of the 16 days that we lost during the shutdown; however, we will try to minimize the impact on programs and IT system development as much as possible. If there are significant impacts we will notify everyone. It will be tough to make up for the lost time concerning physical inspections.
Should Funding Gaps Threaten
As previously reported, LeadingAge staff submitted recommendations to HUD during the shutdown urging proactive policies and administrative relief should funding gaps threaten. During the 2007/2008 period, when owners experienced recurring or extended funding gaps, streamlined policies for access to reserves to cover emergency funding needs were greatly appreciated, and could serve as a model should there be any future such needs.
While funding gaps are not expected, should any member have issues during the return to work, or during/after the CR, please send an email to Colleen Bloom.