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COVID-19 Waivers Being Used By PHA

The Providence Housing Authority (PHA) releases public notice of HUD waivers utilized during COVID-19 pandemic.

HUD-Issued COVID-19 Waivers

The US Department of Housing and Urban Development (HUD) has issued a series of waivers which PHAs may utilize to adopt public housing and housing choice voucher (section 8) program operations to the COVID-19 emergency. The most up to date list of waivers allowed by HUD, which are optional for PHAs, was released on July 2, 2020 in HUD PIH Notice 2020-13 (most waivers were established in an earlier notice in April).

Providence Housing Authority has reviewed the waivers and opted to make use of the following at the present time. PHA will update this document if we determine that we no longer will use any waiver before its expiration date, if the expiration dates are extended, or if we adopt any new waivers listed here.

Any questions on this document may be addressed to inquiries@provhousing.org.

Waivers are listed and explained below in the order they appear in the table provided by HUD with Notice 2020-13.

Key terms & abbreviations:

A full list of commonly used abbreviations and acronyms can be found here.

  • PHA – can either refer to the formal Providence Housing Authority or to public housing authorities in general.
  • PH – Public housing
  • HCV – housing choice voucher, otherwise known as “Section 8”. Below can also be interchanged with “Leased Housing”
  • EIV – Enterprise Income Verification
  • HAP – housing assistance payment contract
  • ACOP- Admissions and Continued Occupancy Policy
  • PBV – Project based voucher

Waivers Related to Both Public & Leased Housing Programs

PH and HCV-2 – Delay of annual reexamination. Permits the PHA to delay the annual reexamination of income and family composition. HCV PHAs must implement HCV-7 for impacted families if they implement this waiver. The public housing program has not adopted this waiver. Leased Housing has adopted this waiver only for use in the Mod Rehab program if needed. Any such delayed re-certifications must be completed by December 31, 2020.

PH and HCV 3 – Annual reexamination income verification. Waives the requirements to use the income hierarchy, including the use of EIV, and will allow PHAs to consider self-certification as the highest form of income verification. PHAs that implement this waiver will be responsible for addressing material income discrepancies that may arise later. For the public housing program, property management will continue to follow the HUD hierarchy for income verification when possible for all annual reexaminations. Self-certifications of income will be accepted from tenants unable to verify their income including email, hard copy letter or a documented phone call.

For the leased housing program, PHA will accept self-certifications from participants unable to verify their income including email, hard copy letter or a documented phone call.

PH and HCV-4 Interim Reexaminations. Waives the requirement to use the income verification requirements, including the use of EIV, for interim reexaminations. For public housing, property management will continue to follow the HUD requirements for income verification when possible for all interim reexaminations. Any deviation will be documented within the tenant file. The Leased Housing program will continue to process interim changes; however, it will waive the use of EIV.

PH and HCV-5 EIV System Monitoring. Waives the mandatory EIV monitoring requirements. Public housing will waive the EIV monitoring requirement. HCV will waive the monitoring requirement but record in a log any households that cannot be validated to avoid delay of any new leases in the future.

PH and HCV 6- Family Self Sufficiency (FSS) Program Contract of Participation. Provides for extensions to FSS contract of participation. Requests for extensions of Family Self Sufficiency contracts will be considered on a case by case basis and will be approved if related to the COVID-19 emergency.

PH and HCV 7 – Waiting List. Waives public notice requirements for opening and closing waiting list. Requires alternative process. If PHA opens or closes a waiting list during the COVID-19 emergency period covered by this waiver, it will notify the public via its website and Facebook page, and will also email community organizations and housing advocacy organizations. 

Waivers Related to Housing Quality Standards Inspections

HQS 1 – Initial Inspection. Changes initial inspection requirements, allowing for owner certification that there are no life-threatening deficiencies. PHA is continuing to require initial inspections conducted by the agency. However, we are currently waiving the required Lead Conformance Certificate, which is a state level requirement for all homes built before 1978 and not owner occupied. An owner without such a certificate must sign a PHA certification that there are no known lead hazards, that the owner has self-inspected the unit for lead hazards, and that the owner will get a lead conformance certificate and submit it to the PHA by December 31, 2020.

HQS 5 – Biennial Inspections. Allows for a delay in biennial inspections. The HCV program has adjusted its policy during COVID-19 to require inspections only every other year. All such biennial inspections required in 2020 will be completed by no later than 1 year later than the date they were due.

HQS 6- Interim Inspections. Waives the requirement for the PHA to conduct interim inspection and requires alternative methods. Allows for repairs to be verified by alternative methods. For any reported housing quality standards violation reported by a tenant or otherwise, Section 8 staff will contact the owner, and allow the owner to self-certify that the issue has been addressed and send a photo or other verification if applicable. Existing time requirements for addressing violations remain in place. Staff will confirm with the tenant that the issue has been addressed.

HQS 10 – HQS Space and Security. Waives the requirement have at least one bedroom or living/sleeping room for each two persons. If tenants request to move into a unit with less than one sleeping room for each two persons, or if a request to add members to the household results in this circumstance, PHA will allow this as long as the change is in accordance with all other HUD regulations. PHA will notify tenants at the time use that this waiver is only allowed for one year from the lease term or until July 2, 2021, whichever is later, per HUD.   

HQS 11 – Homeownership HQS. Waives the requirement to perform an initial HQS inspection in order to begin making homeownership assistance payments. Requires family to obtain independent professional inspection. If a family purchasing a home through the Section 8 homeownership program is required by a lender or otherwise to get a professional inspection, PHA staff will review the results of that inspection to see if there are any HQS violations rather than conduct its own in-person inspection. The PHA may conduct an in-person inspection if the review turns up a potential violation that has not otherwise jeopardized the home purchase.

Waivers Related to Housing Choice Voucher Program

HCV 1 – Administrative Plan – Establishes an alternative requirement that policies may be adopted without Board approval.  The PHA will adopt any program changes that alter the administrative plan no later than September 30, 2020 and will post those changes through any updates to this document or additional documents as needed. The Board of Commissioners will adopt any changes that need to remain in place beyond December 31, 2020 before that date.

HCV 2- PHA Oral Briefing – Waives the requirement for an oral briefing. PHA will brief all new applicants and port-ins via phone call rather than in person, and will email or mail a briefing packet to the participant.

HCV 3- Term of Voucher – Extensions of Term. Allows PHAs to provide voucher extensions regardless of current PHA policy. PHA will provide an additional 60 days to voucher holders whose voucher is in the last 30 days of its 120 day period, so long as the voucher holder has demonstrated best efforts to look for housing during the first 90 days of the voucher term. PHA may consider additional extensions on a case by case basis where a voucher holder has been unable to find and be offered suitable housing.

HCV-4 PHA Approval of Assisted Tenancy.  Provides for HAP payments for contracts not executed within 60 days. If for any reason an owner takes more than 60 days to execute a HAP contract, PHA will still be able to honor the contract using this waiver. However, we are unable to make any HAP payments to an owner until the contract is executed.

HCV-5 Absence from unit. Allows for PHA discretion on absences from units longer than 180 days. On an individual basis, the Director and Associate Director of leased housing will review any extensions to the 180 day absence rule to determine if COVID-19 is a factor. HAP payments for extended absences may not currently be made beyond 12/31/20.

HCV-6 Automatic Termination of HAP Contract. Allows PHA to extend the period of time after the last HAP payment is made before the HAP contract terminates automatically. On a case by case basis, the Director and Associate Director of Leased Housing will consider whether to extend a HAP contract even if a tenant’s income has resulted in zero housing assistance payment for six months, (the usual required time-frame for terminating assistance), and approve if there is a reasonable tenant concern that COVID-19 related circumstances could result in the family qualifying for HAP assistance again before December 31.

HCV-9 Homeownership Counseling. Waives the requirement for the family to obtain pre-assistance counseling. PHA is waiving this requirement but is still offering virtual counseling and referrals to other services as needed.

HCV-13 Homeownership – Max Term. Allows the PHA to extend homeownership assistance up to one additional year. The Director and Associate Director of Leased Housing will consider extension requests for anyone with expiring homeownership assistance on an as needed basis.

HCV-14 Mandatory removal of unit from PBV HAP contract. Allows a PHA to keep a PBV unit under contract for a period of time that extends beyond 180 days from the last HAP but does not extend beyond 12/31/20. The Leased Housing department will consider requests not to remove units from a PBV HAP contract where no HAP has been paid for 180 days. This will not include cases where the unit has been vacant unless there is a continued vacancy as the result of COVID-19 related circumstances.

Waivers Related to Public Housing

PH-4 ACOP. Changes approval process for ACOP. The PHA will adopt any program changes that alter the ACOP no later than September 30, 2020 and posted through any updates to this document or any additional documents as needed. The Board of Commissioners will adopt any changes that need to remain in place beyond December 31, 2020 before that date.

PH-5 CSSR. Temporary suspends community service requirement which applies to some tenants. The PHA has suspended the community service requirement through March 31, 2021.

PH-6 Energy Audits. Allows for the delay in due dates for energy audits. Any energy audits due from PHA to HUD before December 31, 2020 will have their due dates extended by one year.

PH-9 Utility Allowance. Allows for a delay in updating utility allowance schedule. PHA is not updating the utility allowance schedule until December 31, 2020. Changes will be implemented for each tenant household during their re-certification quarter thereafter.

PH-10 Tenant Notifications for Changes to Project Rules and Regulations. Advance notice not required except for policies related to tenant charges. PHA will notify tenants of rule changes as soon as practicable using safe notification methods, including phone, text, email, and in some cases mail. Information will also be posted here at www.ProvHousing.org.

PH-12 Annual Self-Inspections. Waives the requirement that the PHA must inspect each project. PHA will not self-inspect units in calendar year 2020 except for those that were done before the COVID-19 emergency – unless there is an imminent health or safety concern in a particular unit.

Other Waivers & Administrative Relief

Waiver 12c – Deadline for reporting Operating and Capital Fund Expenditures. Provides the PHA a one year extension on closure of all capital fund grants. However, no programmatic expenditure end date shall be extended beyond one month prior to closure of relevant appropriations Annual Contributions Contract (ACC).

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