Thank you, to those of you who have submitted comments regarding the draft HUD Contract Administrative Services procurement, your partnership and shared concern is greatly appreciated.
For those of you who have not yet had an opportunity to read this or respond because of the holiday season, HUD has extended the comment submission date from January 2, 2018 to January 31, 2018 allowing folks more time to digest the draft and submit comments.
This is to alert you to changes the Department of Housing and Urban Development (HUD) is considering that could impact the administration of your development's Project Based Section 8 contract.
Earlier this month, HUD issued draft solicitation that would replace the current Performance Based Contract Administrator (PBCA) process with a system administered directly by HUD. Instead of New Hampshire Housing serving as your single point of contact, Project Based Section 8 contract administration services would be divided between national and regional agencies selected by HUD. Under this proposal, Project Based Section 8 developments could expect the following:
Multiple Contacts for Contract Administration: HUD proposes to contract with both national and regional agencies to provide Housing Assistance Payment (HAP) Contract Support Services in place of current local contract administrators. National agencies would provide portfolio analysis, risk assessment, HAP contract renewal processing and rent adjustment processing. Regional agencies would provide management and occupancy reviews, respond to tenant health and safety concerns and process your vouchers and special claims. Your Housing Assistance Payments will be sent to you directly from Treasury. The regional agency will not be able to provide you with any updates on anticipated payments, funding delays or renewals of contracts.
Multiple Management and Occupancy Reviews (MORs): HUD's draft solicitation could result in multiple MORs having to be conducted on the same property within the same year. In addition, Owner/Agents with New Hampshire Housing financing will need to separately meet those reporting and monitoring requirements.
Potential Loss of Technical Assistance & Training: The draft solicitation does not include requirements for vendors to provide any of the technical assistance, training, preservation tools and compliance support that New Hampshire Housing has provided to Owner/Agents over the years.
The link below is to HUD's draft solicitation. You may want to review this solicitation to assess potential impacts to your Multifamily Section 8 development. If you have concerns, you may provide comments to HUD by January 31, 2018. This is HUD's deadline and any comments received after this date may not be considered. To view the solicitation, please go to the following link:
Please note that the Revised Draft with the January 31, 2018 deadline is located on the right side of this page as "HAPRSS Revised Draft RFP 86546A18R00002."
If you wish to share feedback to HUD you may provide any feedback you feel appropriate. Attached is an example of a draft comment letter that captures some of the issues explained above. You may work off this letter if these are concerns you share. We also encourage you to consult with any professional organizations to which you may belong (iREM, NEAHMA, etc.) and work with them to submit comments as appropriate. Comments should be emailed to HAPRSS@hud.govby the submission deadline of January 31, 2018.
Thank you for your continued partnership in providing quality, affordable housing for New Hampshire residents. Feel free to contact me, Marie Poole, at 603-310-9256 or via email at mpoole@nhhfa.org with any questions, comments or concerns that you may have.
