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Home My WebLink About20A - AA FOR HOUSING AUTHORITY ADMIN VOUCHERREQUEST FOR COUNCIL ACTION CITY COUNCIL MEETING DATE: JUNE 2, 2020 TITLE APPROVE APPROPRIATION ADJUSTMENTS RECOGNIZING $598,916 OF HOUSING AUTHORITY ADMINISTRATIVE FEE FUNDING AND $2,828 IN MAINSTREAM VOUCHER PROGRAM ADMINISTRATIVE FEES (NON -GENERAL FUND) CLERK OF COUNCIL USE ONLY: APPROVED ❑ As Recommended ❑ As Amended ❑ Ordinance on 111 Reading ❑ Ordinance on 2ntl Reading ❑ Implementing Resolution ❑ Set Public Hearing For_ CONTINUED TO /s/ Kristine Ridge FILE NUMBER CITY MANAGER RECOMMENDED ACTION Approve an appropriation adjustment recognizing additional Housing Choice Voucher Program and Mainstream Voucher administrative funds in the amount of $601,744 in revenue account (no. 15718002-52000) and appropriating the same amount to expenditure account (nos. 15718760- various). DISCUSSION The Housing Authority of the City of Santa Ana administers the Housing Choice Voucher (HCV) program as one of four public housing agencies in Orange County On May 7, 2020, the Housing Authority received an allocation of $598,916 in HCV and $2,828 in Mainstream Voucher Program administrative fee funding to prevent, prepare for, and respond to the coronavirus (Exhibit 1). The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) provides funding to prevent, prepare for, and respond to coronavirus, including for public housing agencies to maintain normal operations and take other necessary actions during the period the program is impacted by coronavirus. The total supplemental appropriation for the Housing Choice Voucher (HCV) Program nationally is $1.25 billion with $850 million allocated for administrative fees. This administrative fee funding may be used by public housing agencies (PHAs) for administrative expenses and other expenses related to coronavirus. Under the CARES Act, this supplemental administrative fee funding may be used only for two purposes: (1) any currently eligible HCV (including Mainstream voucher) administrative costs during the period that the program is impacted by coronavirus; and (2) new coronavirus-related activities, including activities to support or maintain the health and safety of assisted individuals and families, and costs related to the retention and support of participating owners. Within section (1), currently eligible HCV administrative costs include necessary upgrades to information technology or computer systems to enhance telework capacities to carry out HCV Program responsibilities. 20A-1 Appropriation Adjustment — HCV CARES Act Admin Funds June 2, 2020 Page 2 Staff intends to use approximately $75,000 of these fees to complete necessary upgrades to information technology or computer systems resulting in the Housing Authority's business continuity during the COVID related crisis, or the next such emergency that may come our way. Business continuity has been disrupted and this is an opportunity to improve the Housing Authority's agility. The remaining portion will be used for on -going eligible administrative expenses incurred by the Housing Authority during this pandemic in response to the coronavirus. A description of new eligible coronavirus-related activities was provided by the U.S. Department of Housing and Urban Development in Public and Indian Housing Notice 2020-08 (Exhibit 2). STRATEGIC PLAN ALIGNMENT Approval of this item supports the City's efforts to meet Goal #5 - Community Health, Livability, Engagement & Sustainability, Objective #3 (facilitate diverse housing opportunities and support efforts to preserve and improve the livability of Santa Ana neighborhoods). FISCAL IMPACT Approval of the appropriation adjustment will recognize $601,744 in the revenue account and increase the expenditure accounts as follows: Revenues Fiscal Year Accounting Unit- Fund Description Accounting Unit, Account Amount Account Description FY 19-20 15718002-52000 Housing Admin Federal Grant -Direct $601,744 Ma CARES Act Total Revenues $601,744 Expenditures Fiscal Year Accounting Unit- Fund Description Accounting Unit, Account Amount Account Description FY 19-20 15718760-various Housing Admin Housing Admin CARES Act $252 828 (June) CARES Act COVID-19, Various FY 20-21 15718760-various Housing Admin Housing Admin CARES Act $348,916 Jul -Dec. CARES Act COVID-19, Various Total Expenditures $601,744 The expenditure spending plan is only an estimate and subject to change. Any amount unspent in June 2020 from the projected will be carried forward for expenditure in FY 20-21. Exhibits: 1. Allocation Letter from HUD 2. Public and Indian Housing Notice 2020-08 20A-2 U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT IIIIIIII Q 4,. WASHINGTON, DC 20410-5000 OFFICE OF PUBLIC AND INDIAN HOUSING Dear Executive Director Subject: Initial Administrative Fee Allocation from the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). The Office of Housing Voucher Programs (OHVP) has allocated the initial administrative fee funding per the CARES Act (Public Law 116-136) to public housing agencies (PHAs) administering the Housing Choice Voucher (HCV) Program and/or the Mainstream Program. PHAs must use these funds to prevent, prepare for, and respond to coronavirus (COVID-19), per guidance provided in PIHNotice 2020-08: CARESAct—HCVProgram Administrative Fees. https://www.hud.gov/program offices/public_indian housing/publications/notices This initial administrative fee award provided to each agency through the CARES Act is described in the attached Enclosure A. The calculation determined the monthly average administrative fees based on the PHAs reconciled calendar year (CY) 2018 and 2019 eligibilities, divided by 12 months, then multiplied by 2. HUD will provide separate guidance on the allocation of the remaining CARES Act administrative fee funds. Additionally, it is anticipated that a notice describing the allocation criteria and methodology for the Housing Assistance Payments (HAP) portion of the CARES Act will be posted in June 2020. Finally, the OHVP guidance regarding the tracking and reporting of the CARES Act funding is forthcoming. In the meantime, PHAs must follow the preliminary guidance provided in section 7. Reporting Requirements, of PIH Notice 2020-08. Please direct any questions concerning this allocation to contact your Financial Analyst at the Financial Management Center. Thank you for your continued participation in the HCV and/or Mainstream Programs to serve the needs of your community during this critical time. Enclosure Sincerely, I' Dg�kM'uA,aaFenanee. Miguel A. Fontana V ia� ou=saw rssaeun: i amapproYlg/saocummnt Miguel A. Fontanez Director Housing Voucher Financial Management Division Niirw.hud.no}� O� _��nol.hud.nov CARES Act — HCV Program Administrative Fees Enclosure A 1 PHA Number 2 PHA Name Regular Voucher Program 3 CY 2018 Administrative Fee Total Eligibility 4 CY 2019 Administrative Fee Total Eligibility Average of CY 2018 and CY 2019 (Line 3 plus 5 Line 4 divided by 2) 6 Monthly Average (Line 5 divided by 12) Regular Voucher Program Total Award (Line 6 7 multiplied by 2) Mainstream Voucher Program 8 CY 2018 Administrative Fee Total Eligibility 9 CY 2019 Administrative Fee Total Eligibility 10 Average of CY 2018 and CY 2019 (Line 8 plus 11 Line 9 divided by 2) 12 Monthly Average (Line 11 divided by 12) Mainstream Voucher Program Total Award 13 (Line 12 multiplied by 2) CA093 CITY OF SANTA ANA HSG AUTH $ 3,593,497 $ 299,458 $ 3,521,626 $ 3,665,368 $ 598,916 $ $ 33,945 20A-4 EXHIBIT 2 U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT WASHINGTON, DC 20410-5000 OFFICE OF PUBLIC AND INDIAN HOUSING Special Attention of: Office Directors of Public Housing, Regional Directors, and Public Housing Agencies. P 1 Notice PIH-2020-08 Issued: April 28, 2020 Expires: This notice remains in effect until amended, superseded, or rescinded Cross References: PIH Notice 2020-04 SUBJECT: CARES Act—HCV Program Administrative Fees 1. Purpose. This notice implements the funding provisions for the Housing Choice Voucher (HCV) and Mainstream Programs in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) (Public Law 116-136), enacted on March 27, 2020. The CARES Act provides additional appropriations for housing assistance payments (HAP) and administrative fee funding to prevent, prepare for, and respond to coronavirus. The Tenant -Based Rental Assistance portion of the CARES Act is attached as Appendix A. This notice addresses HUD's allocation methodology for the administrative fee portion of this appropriation and establishes new eligible activities to prevent, prepare for, or respond to coronavirus that may be funded with these supplemental administrative fee amounts. 2. Summary. The CARES Act provides funding to prevent, prepare for, and respond to coronavirus, including for public housing agencies to maintain normal operations and take other necessary actions during the period the program is impacted by coronavirus. The total supplemental appropriation for the HCV Program is $1.25 billion. This notice covers the administrative fee portion totaling $850 million for HCV Programs, including the Mainstream Program, which provides tenant -based vouchers that serve households that include a non -elderly person with a disability under competitive awards. This administrative fee funding may be used by public housing agencies (PHAs) for administrative expenses and other expenses related to coronavirus, which are new eligible activities defined by the Secretary in section 4 of this notice. HUD will obligate the supplemental administrative fee amounts in several actions. This notice describes the initial funding action in the approximate amount of $380 million. Forthcoming guidance will describe the allocation methodology of the remaining ($470 million) supplemental administrative fee funding. Additionally, HUD will issue a separate 20A-5 EXHIBIT 2 notice describing the allocation methodology and the requirements governing the HAP supplemental funding ($400 million). 3. Funding Methodology. The CARES Act provides administrative fee funding for both the HCV and Mainstream Programs. HUD will provide approximately $380 million (the equivalent of 2-months of administrative fee eligibility) to all PHAs, including Moving to Work (MTW) PHAs. This first funding action will be allocated as a single disbursement at the beginning of May 2020. The amount of funding PHAs receive in this disbursement equals the average of the PHA's calendar year (CY) 2018 and CY 2019 monthly administrative fee eligibility (100% proration) multiplied by two. 4. Eligible Expenses for CARES Act funds as well as administrative fees under the FY 2020 Appropriations Act. Under the CARES Act, this supplemental administrative fee funding may be used only for two purposes: (1) any currently eligible HCV (including Mainstream voucher) administrative costs during the period that the program is impacted by coronavirus; and (2) new coronavirus-related activities, including activities to support or maintain the health and safety of assisted individuals and families, and costs related to the retention and support of participating owners. Currently eligible HCV administrative costs under (1) include necessary upgrades to information technology or computer systems to enhance telework capacities and overtime pay for PHA staff to carry -out HCV Program responsibilities. The CARES Act further provides that administrative fees appropriated under HUD's FY 2020 Appropriations Act (P.L.116-94) for the regular HCV program may also be used for the new coronavirus-related activities. Mainstream program administrative fees appropriated under HUD's FY 2020 Appropriations Act are not eligible to be used for these new coronavirus-related activities. However, PHAs may use the supplemental fees to cover any of the new coronavirus-related activities listed below in support of their Mainstream voucher programs. The new eligible coronavirus-related activities are: • Procuring cleaning supplies and/or services to maintain safe and sanitary HCV units, including common areas of PHA -owned Project Based Voucher (PBV) projects. • Relocation of participating families to health units or other designated units for testing, hospitalization, or quarantine, or transportation to these locations to limit the exposure that could be caused by using mass transportation. • Additional costs to supportive services vendors incurred due to coronavirus. • Costs to retain or increase owner participation in the HCV Program, such as incentive costs (e.g., the PHA offers owner an incentive payment to participate in recognition of added difficulties of making units available for HCV families to rent while stay-at-home orders or social distancing practices are in effect.) • Costs for providing childcare for the children of PHA staff that would not have otherwise been incurred (e.g., children are at home due to school closings, PHA staff are working outside of regular work schedules, etc.). 20A-6 EXHIBIT 2 • Costs associated with the delivery of goods, including food and medical supplies that comply with the Centers for Disease Control (CDC) requirements, to program participants. • Public health -related security costs to enforce orders to shelter -in -place, stay-at-home orders or visitor -restriction policies for PHA owned PBV projects. • Administration costs associated with the implementation of coronavirus-related activities that are not eligible HCV administrative costs (e.g., paying overtime to staff to carry -out these coronavirus-related activities). • Other costs either directly or indirectly related to coronavirus as determined eligible on a case -by -case basis at the Secretary's discretion. o PHAs requesting approval to cover other coronavirus-related activities not included in the above list and not currently eligible as regular HCV administrative costs must send the request and an explanation of the proposed activity to the FinancialManagementCenter(a),hud.gov mailbox. The subject line of the email should read "PHA# Requesting Eligibility for Coronavirus-Related Administrative Cost", example "TX001 Requesting Eligibility for Coronavirus-Related Administrative Cost". Requests will be reviewed on a periodic basis. As additional eligible costs are approved, HUD will update the list of eligible activities and maintain the most current list of eligible coronavirus-related activities on our website https://www.hud.gov/program offices/public indian housing/programs/hcv. Period of Availability: Under the CARES Act, these supplemental administrative fee funds may be used for both HCV (including Mainstream) administrative expenses and the new coronavirus-related activities during the period that the program is impacted by coronavirus. HUD recognizes that the HCV Program will continue to be impacted by coronavirus well beyond the immediate challenges of operating during shelter-in-place/stay-at-home orders or recommended social distancing practices. Program operations will continue to be impacted as PHAs transition back to full operational capacity, comply with applicable alternative requirements in accordance with the CARES Act waivers provided under PIH Notice 2020- 05, and manage calendar year leasing and utilization challenges created by the coronavirus earlier in the year. Consequently, the period of availability for these funds is the duration of calendar year 2020, unless this period is subsequently extended by HUD. Similarly, the fiscal year (FY 2020) HCV administrative fee funds may be used for coronavirus related purposes in addition to the eligible HCV administrative expenses for the duration of CY 2020. The funding provided through this notice may only be used for the two purposes described in this notice. Unlike regular administrative fees, these funds may not roll into the unrestricted net position (UNP) and must be tracked and accounted for separately throughout the period of availability. If any of these funds are not expended during the period of availability, the remaining funds must be remitted to HUD. Accounting and remittance guidance will be forthcoming. Notwithstanding this period of availability, HUD urges PHAs to expend this supplemental administrative fee funding first, to prevent, prepare for, and respond to coronavirus. To 20A-7 EXHIBIT 2 maximize program offerings during the ongoing pandemic, HUD recommends that PHAs apply their supplemental administrative fee amounts to eligible expenses first, since the HCV Program FY 2020 administrative fees may also be used for coronavirus-related activities within the period of availability and will continue to be available for regular administrative fee purposes beyond the period of availability. 5. Ineligible Expenses. The funding provided through this notice cannot be used for the repayment of debts or any amounts owed to HUD or program participants including, but not limited to, Office of Inspector General (OIG), Quality Assurance Division (QAD) or other monitoring review findings. Additionally, administrative fee funds provided through this notice considered for salaries, bonuses and/or employee incentives must comply with the executive compensation requirements under Section 220 of Public Law No. 116-94, Further Consolidated Appropriations Act, 2020 and must comply with reasonable compensation requirements found at 2 CFR Part 200.430(b). 6. Use of PHA's Remaining DHAP Funds for Coronavirus-Related Activities. Per the April 1, 2020 letter provided to applicable PHAs with Federal Emergency Management Agency (FEMA) Disaster Housing Assistance Program (DHAP) funding for: (1) Hurricanes Katrina and Rita (DHAP-Katrina) and (2) Hurricanes Ike and Gustav (DHAP-Ike), such funding may be used towards coronavirus-related expenses as carry-over funds. Per the Standard Operating Procedures (SOPS) for both programs, prepared by FEMA and HUD, any administrative fee funds remaining at the end of these programs must be used "for disaster or emergency related purposes." On March 13, 2020, President Trump declared the coronavirus pandemic of sufficient severity and magnitude to warrant an emergency declaration for all states, tribes, territories, and the District of Columbia pursuant to section 50l(b) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. 5121-5207, qualifying any remaining DHAP-Ike or Katrina administrative funds. 7. Reporting Requirements. HUD will develop a process by which PHAs will report all expenditures of CARES Act supplemental funds, including the date, amount, and use of such funds. Guidance implementing this process is forthcoming. To ensure PHAs have the ability to report to HUD on these expenses, PHAs must track coronavirus revenue and expenses by creating coronavirus Profit and Loss (P&L) accounts. Guidance for reporting coronavirus financial information to the Financial Assessment Subsystem (FASS) is forthcoming. Additional CARES Act Reporting Section 15011 of the CARES Act requires that recipients of $150,000 or more of CARES Act funding submit, not later than 10 days after the end of each calendar quarter, a report containing information regarding the amount of funds received; the amount of funds obligated or expended for each project or activity; a detailed list of all such projects or activities, including a description of the project or activity; and detailed information on any subcontracts or subgrants awarded by the recipient. As outlined in the Office of 20A-8 EXHIBIT 2 Management and Budget (OMB) memorandum, M-20-21, existing reporting requirements are anticipated to meet the requirements of Section 15011, but the content and format for this reporting is still under development and will need to be reviewed against current program practices. The Department will work in coordination with OMB to ensure that this requirement can be fulfilled by recipients of CARES Act funding in a manner that utilizes to the greatest extent possible existing reporting streams, providing the necessary transparency and accountability with minimal additional burden. If additional reporting is necessary, further guidance will be released by the Department in the near future. 8. Excluded Programs. The provisions implemented by this notice do not apply to renewal funding for the Section 8 Moderate Rehabilitation Program or the Section 8 Moderate Rehabilitation Single Room Occupancy Program. 9. Paperwork Reduction Act. The information collection requirements (ICR) for the HCV and Mainstream Programs are approved by the Office of Management and Budget (OMB) under the Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520). The OMB control number is 2577-0169. As noted in item 7 above, the reporting requirements to comply with the CARES Act will be forthcoming. 10. Further Information. Direct questions to HCV Financial Management Division (FMD), Office of Public Housing and Voucher Programs, by email, at PH-IFinancialManagementDivision@hud.gov. R. Hunter Kurtz, Assistant Secretary for Public and Indian Housing 20A-9 EXHIBIT 2 Appendix A CARES Act (Public Law 116-136) For an additional amount for "Tenant -Based Rental Assistance", $1,250,000,000, to remain available until expended, to prevent, prepare for, and respond to coronavirus, including to provide additional funds for public housing agencies to maintain normal operations and take other necessary actions during the period that the program is impacted by coronavirus: amounts made available under this heading in this Act, $850,000,000 shall be available for both administrative expenses and other expenses of public housing agencies for their section 8 programs, including Mainstream vouchers: Provided further, That such other expenses shall be new eligible activities to be defined by the Secretary and shall include activities to support or maintain the health and safety of assisted individuals and families, and costs related to retention and support of participating owners: Provided further, That amounts made available under paragraph (3) under this heading in Public Law 116-94 may be used for such other expenses, as described in the previous proviso, in addition to their other available uses: Provided further, That of the amounts made available under this heading in this Act, $400,000,000 shall be available for adjustments in the calendar year 2020 section 8 renewal funding allocations, in addition to any other appropriations available for such purpose, including Mainstream vouchers, for public housing agencies that experience a significant increase in voucher per -unit costs due to extraordinary circumstances or that, despite taking reasonable cost savings measures, as determined by the Secretary, would otherwise be required to terminate rental assistance for families as a result of insufficient funding Provided further, That the Secretary shall allocate amounts provided in the previous proviso based on need, as determined by the Secretary: Provided further, That the Secretary may waive, or specify alternative requirements for, any provision of any statute or regulation that the Secretary administers in connection with the use of the amounts made available under this heading and the same heading of Public Law 116-94 (except for requirements related to fair housing, nondiscrimination, labor standards, and the environment), upon a finding by the Secretary that any such waivers or alternative requirements are necessary for the safe and effective administration of these funds, consistent with the purposes described under this heading in this Act, to prevent, prepare for, and respond to coronavirus: Provided further, That the Secretary shall notify the public through the Federal Register or other appropriate means of any such waiver or alternative requirement to ensure the most expeditious allocation of this funding, and in order for such waiver or alternative requirement to take effect, and that such public notice may be provided, at a minimum, on the Internet at the appropriate Government web site or through other electronic media, as determined by the Secretary: Provided further, That any such waivers or alternative requirements shall remain in effect for the time and duration specified by the Secretary in such public notice and may be extended if necessary upon additional notice by the Secretary: Provided further, That to prevent, prepare for, and respond to coronavirus, the notification required by section 223 of Public Law 116-6 and section 221 of Public Law 116-94 shall not apply to the award of amounts provided under paragraph (2) of this heading in Public Lawl 16-6 or under paragraph (7)(B) of this heading in Public Law 116-94 in support of the family unification program under section 8(x) of such Act: Provided further, That the Secretary may award any remaining unobligated balances appropriated under this heading in prior Acts for incremental tenant -based assistance contracts under section 811 of the Cranston -Gonzalez National Affordable 23 Housing Act (42 U.S.C. 8013), to prevent, prepare for, and respond to coronavirus, without competition, including for extraordinary administrative fees: Provided further, That no less than 25 percent of such amounts shall be allocated proportionally to public housing agencies who received awards in the 2017 and 2019 competitions for such purposes within 60 days of enactment of this Act: Provided further, That the waiver and alternative requirements authority provided under this heading in this Act shall also apply to such incremental tenant -based assistance contract amounts: Provided further, That such amount is designated by the Congress as being for an emergency requirement pursuant to section 251(b)(2)(A)(i) of the Balanced Budget and Emergency Deficit Control Act of 1985. 20A-10