Have MFH Field Offices been given guidance on how housing providers should prepare and respond to COVID-19? The Office of MFH provides regular direction to field staff. On March 3, the Office sent an email message to external stakeholders that encouraged stakeholders to share information from the Centers for Disease Control and Prevention (CDC) on the Coronavirus with residents, stakeholders, and others. Please see the following information regarding Emergency Preparedness, Planning, Identification and Messaging for Aging and Disabled Networks: https://www.naccho.org/uploads/downloadable-resources/Capacity-Building-Toolkit-for-Aging- and-Disability-Networks-2-5-19.pdf
What emergency funds can owners and agents access for outbreak preparedness and response (including extra supplies, additional administrative hours, and staff overtime), and what kind of approval do housing providers need from HUD in order to access the funds? Multifamily property owners and agents can access property operating accounts for all reasonable and necessary COVID-19 related preparedness and response actions, including supplies, staff hours, and overtime. No advance HUD approval is required to access operating account funds.
To the extent that owner advances are required, owners should receive HUD approval in advance, especially if the owner expects repayment before the distribution of annual (or semi-annual) surplus cash. For those properties with reserve for replacement accounts and residual receipts accounts, funds should be accessed according to current policy in Handbook 4350.1, Chapter 4 (for reserve for replacement accounts), for eligible items. If the owner is seeking to use reserve for replacement and residual receipt funds for non-eligible uses, approval must be received from HUD field staff in advance.
In light of concerns about site visits to HUD properties, what is the status of REAC inspections on MFH properties? Until further notice, Multifamily is postponing all REAC property inspections for all Multifamily properties. Where there is an exigent circumstance or reason to believe that there is a threat to life or property at a specific location, inspections will be conducted by HUD quality assurance inspectors in compliance with CDC guidelines. Please note, this answer supersedes the initial guidance offered in the first version of this document on 3/12/20.
In light of concerns about site visits to HUD properties, what is the status of Management and Occupancy Reviews (MORs) performed by Performance-Based Contract Administrators (PBCAs)? HUD recognizes that the President’s March 13, 2020, emergency determination related to COVID-19 constitutes a significant administrative action that could disrupt performance under the Annual Contributions Contracts (ACC). HUD is hereby relieving PBCAs operating under both ACCs from notifying HUD that the Presidential emergency determination either limits, or in some cases, prevents, PBCAs from carrying out MORs and related activities. HUD is therefore suspending standard MORs until the PBCA determines that local conditions no longer limit or prevent the PBCA from performing MORs safely.
HUD is looking into a flexible model that would allow PBCAs to adapt to local conditions in a way that allows them to continue MORs on a modified basis to ensure acceptable conditions in HUD properties. Additional guidance and specifications will be forthcoming.
Please note, this answer supersedes the initial guidance offered in an earlier version of this document on 3/13/20.
In the event of HUD office closures and/or staff working remotely, what will be the process for subsidy contract renewals and funding actions? Multifamily field and headquarters staff will process subsidy contract renewals and related funding actions remotely. Contract renewals and funding actions should still be submitted electronically via the local or Regional office email box, with a copy to the assigned Account Executive/Resolution Specialist, the Funding Specialist, and Branch Chief. Hard copies should still be submitted to the field office.
In the event of office closures, how will MFH Production handle the submission of applications since typically HUD requires an original and two hard copies of the application along with a physical thumb drive for certain types of projects? HUD will permit applications and related documents to be submitted electronically, using a secure cloud storage service, as determined by the lender, instead of hard copies. HUD will arrange for architectural plans and specifications to be sent to the processing construction analyst identified at the concept meeting to be reviewed remotely.
